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TOLLEFSEN v. COMMISSIONER

Docket No. 1743-67.

52 T.C. 671 (1969)

GEORGE R. TOLLEFSEN AND MARGARET A. TOLLEFSEN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed July 24, 1969.

Attorney(s) appearing for the Case

Murray Kurman, for the petitioners.

Richard J. Mandell, for the respondent.

The Commissioner determined a deficiency in petitioners' 1961 income tax in the amount of $13,029.91. The only issue is whether $24,665.40 received by petitioner George R. Tollefsen during 1961 from Tollefsen Manufacturing Corp., a corporation controlled by him, is taxable to petitioners as a dividend under sections 301 and 316, I.R.C. 1954.

FINDINGS OF FACT

Some of the facts are stipulated and are incorporated herein...

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