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SPA BUILDING CORPORATION v. COMMISSIONER

Docket No. 1600-72.

33 T.C.M. 179 (1974)

T.C. Memo. 1974-37

SPA Building Corporation v. Commissioner.

United States Tax Court.

Filed February 7, 1974.

Attorney(s) appearing for the Case

E. Richard Criss, Jr., 900 Brown Bldg., Austin, Tex., for the petitioner. David L. Jordan, for the respondent.

Memorandum Findings of Fact and Opinion

FEATHERSTON, Judge:

Respondent determined a deficiency in the amount of $7,362.69 in petitioner's income tax for the taxable year ended March 31, 1969. The only issue for decision is whether $14,000 received by petitioner on March 5, 1968, from The Spa Health and Beauty Resort of Lubbock, Texas, Inc., was prepaid rent, as contended by petitioner, or a loan, as determined...

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