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ESTATE OF BAYNHAM v. COMMISSIONER

Docket No. 360-64.

25 T.C.M. 310 (1966)

T.C. Memo. 1966-54

Estate of Leslie B. Baynham, Deceased, First Security National Bank & Trust Company, Administrator, and Elizabeth W. Baynham v. Commissioner.

United States Tax Court.

March 16, 1966.

Attorney(s) appearing for the Case

William R. Bagby, 1107 First Nat'l Bank Bldg., Lexington, Ky., for the petitioners. Sanford S. Neuman, for the respondent.

Memorandum Findings of Fact and Opinion

BRUCE, Judge:

Respondent determined deficiencies in income tax for the calendar years 1958, 1959, and 1960 in the respective amounts of $4,637.52, $14,699.76, and $15,985.27. The sole issue remaining for decision is whether payments made in 1958 and 1959 by a corporation controlled by Leslie B. and Elizabeth W. Baynham to creditors of another corporation also controlled by them represented constructive dividends to...

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