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PECO COMPANY v. COMMISSIONER

Docket No. 908-66.

26 T.C.M. 207 (1967)

T.C. Memo. 1967-41

Peco Company v. Commissioner.

United States Tax Court.

Filed March 2, 1967.

Attorney(s) appearing for the Case

Peter Meloy, 555 Fuller Ave., Box 1699, Helena, Mont., John R. Kline, and J. Patrick Giblin, for the petitioner. Lee A. Kamp, for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

Respondent determined deficiencies in petitioner's income taxes for the fiscal years ended October 31, 1962, and October 31, 1963, in the respective amounts of $763.22 and $200.26.

The primary issue presented for our decision is whether advances by stockholders to petitioner-corporation were capital contributions, thus making purported interest payments...

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