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MARKS v. COMMISSIONER

Docket No. 88361.

22 T.C.M. 1600 (1963)

T.C. Memo. 1963-304

Louis Marks and Nettie Marks v. Commissioner.

United States Tax Court.

Filed November 4, 1963.

Attorney(s) appearing for the Case

Edward Newman, 11 E. 44th St., New York, N. Y., for the petitioners. Eugene L. Wilpon, for the respondent.

Memorandum Findings of Fact and Opinion

OPPER, Judge:

Respondent determined deficiencies in income tax for the calendar years 1953, 1954, and 1955 in the amounts of $15,297.06, $5,447.62, and $749.02, respectively. A part of respondent's determinations are not questioned in the petition. The issues for decision are (1) whether petitioners received corporate distributions constituting constructive dividends in 1953, 1954, and 1955 in the amounts of $21,216...

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