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NICHOLS v. COMMISSIONER

Docket No. 2485-71.

32 T.C.M. 507 (1973)

T.C. Memo. 1973-114

Wayne B. Nichols v. Commissioner.

United States Tax Court.

Filed May 21, 1973.

Attorney(s) appearing for the Case

Wayne B. Nichols, pro se, 177 Second St., Barberton, Ohio. Wright Tisdale, Jr., for the respondent.

Memorandum Findings of Fact and Opinion

SCOTT, Judge:

Respondent determined a deficiency in petitioner's income tax in the amount of $1,927 for the taxable year 1967.

The issue for decision is whether petitioner received a constructive dividend under section 301(a) of the Internal Revenue Code of 1954,1 in the amount of $7,500 when his controlled corporation redeemed the stock...

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