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HODGKINS v. COMMISSIONER

Docket No. 2780-63.

24 T.C.M. 1149 (1965)

T.C. Memo. 1965-225

Estate of Frances B. Hodgkins, Deceased, Joan H. Gould and David L. Hodgkins, Executors v. Commissioner.

United States Tax Court.

Filed August 20, 1965.

Attorney(s) appearing for the Case

Charles H. Burton, for the petitioner. Robert B. Dugan, for the respondent.

Memorandum Findings of Fact and Opinion

MULRONEY, Judge:

Respondent determined a deficiency in the income tax of Frances B. Hodgkins for 1959 in the amount of $2,486.90. The issue is whether distributions by Forster Mfg. Co., Inc., during 1959 to David L. Hodgkins and Joan H. Gould are includable as constructive dividends in the income of Frances B. Hodgkins to the extent of her stock ownership in the corporation.

Findings of Fact

Some...

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