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SHEPHARD v. COMMISSIONER

Docket No. 93373.

22 T.C.M. 1502 (1963)

T.C. Memo. 1963-294

Rita G. Shephard, Guardian of Susan Shephard v. Commissioner.

United States Tax Court.

Filed October 25, 1963.

Attorney(s) appearing for the Case

William R. Bagby, 615 First National Bank Bldg., Lexington, Ky., and Morris B. Floyd, for the petitioner. W. Dean Short, for the respondent.

Memorandum Findings of Fact and Opinion

HOYT, Judge:

Respondent determined a deficiency in income tax in the amount of $8,687.50 for the year 1958 against petitioner as transferee of the assets of the Estate of Clarence E. Shephard, Deceased. The sole issue to be decided is whether or not there was a forgiveness of an indebtedness in the amount of $24,241.32 to Clarence E. Shephard in 1958 by Croppers Laundry, Inc., which constituted a taxable dividend to...

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