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FERRO v. COMMISSIONER

Docket No. 52459.

15 T.C.M. 485 (1956)

T.C. Memo. 1956-94

David A. Ferro and Elizabeth N. B. Ferro v. Commissioner.

United States Tax Court.

Filed April 25, 1956.

Attorney(s) appearing for the Case

George F. Shinehouse, Jr., Esq., Commercial Trust Building, Philadelphia, Pa., for the petitioners. John D. Armstrong, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

WITHEY, Judge:

The Commissioner has determined a deficiency of $7,692.18 in the petitioners' income tax for 1950. The only issue presented is whether during 1950 the petitioners constructively received a dividend of $20,000 from the corporation of which they were the sole stockholders.

Findings of Fact

The stipulated facts are found as stipulated.

The petitioners are husband and wife who timely...

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