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S. P. REALTY CO., INC. v. COMMISSIONER

Docket No. 831-67.

27 T.C.M. 764 (1968)

T.C. Memo. 1968-156

S. P. Realty Co., Inc. v. Commissioner.

United States Tax Court.

Filed July 23, 1968.

Attorney(s) appearing for the Case

Robert K. Hartmann, Hasbrouck Hts., N. J., for the petitioner. Owen A. Knopping, for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

Respondent determined the following income tax deficiencies against the petitioner:

  Taxable Year Ended    Deficiency

  June 30, 1962..........    $2,091.78
  June 30, 1963..........    1,552.50
  June 30, 1964..........    1,437.69

The only issue for decision is whether certain advances made to petitioner by its three shareholders were contributions to capital or loans...

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