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GRANZOTTO v. COMMISSIONER

Docket No. 3758-69.

30 T.C.M. 457 (1971)

T.C. Memo. 1971-106

Carlotta Granzotto v. Commissioner.

United States Tax Court.

Filed May 17, 1971.

Attorney(s) appearing for the Case

Charles A. Wood, Jr., Locust and Bonanza Sts., Walnut Creek, Calif., for the petitioner. John Gigounas, for the respondent.

Memorandum Findings of Fact and Opinion

SCOTT, Judge:

Respondent determined deficiencies in petitioner's income tax for the calendar years 1962, 1963, and 1964 in the amounts of $14,542.84, $12,752.30 and $9,147.31, respectively.

The sole issue for decision is whether cash transfers from the Granzotto Trucking Co., Inc., to the petitioner in each of the taxable years in issue were loans to petitioner or...

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