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MAHER v. COMMISSIONER

Docket Nos. 2916-67, 4667-69, 4668-69.

56 T.C. 763 (1971)

RAY A. MAHER AND ROSE M. MAHER, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT RAY A. MAHER, TRANSFEREE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 12, 1971.

Attorney(s) appearing for the Case

John J. Alder and A. Henry Cuneo, for the petitioners.

Larry K. Hercules, for the respondent.

SUPPLEMENTAL OPINION

FORRESTER, Judge:

On December 10, 1970, we filed our opinion in this case, 55 T.C. 441, wherein we held, in part, that Ray A. Maher (hereinafter sometimes referred to as Ray).had received a constructive dividend in 1963 when Selectivend Corp. (hereinafter sometimes referred to as Selectivend) assumed payments on his personal promissory notes.

On January 12, 1971, petitioners filed a "Motion...

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