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PATMON, YOUNG & KIRK PROFESSIONAL CORPORATION v. COMMISSIONER

Docket No. 9196-73.

34 T.C.M. 798 (1975)

T.C. Memo. 1975-185

Patmon, Young & Kirk Professional Corporation v. Commissioner.

United States Tax Court.

Filed June 12, 1975.

Attorney(s) appearing for the Case

Stanley R. Kirk (an officer), 2429 Cadillac Tower, Detroit, Mich., for the petitioner. James E. Keeton, Jr., for the respondent.

Memorandum Opinion

TIETJENS, Judge:

The Commissioner determined a deficiency of $549.91 in petitioner's Federal income tax for the taxable year ended October 31, 1970.

The sole question for decision is whether petitioner's contribution in the form of a demand promissory note to its employees profit-sharing trust meets the "paid" requirement of section 404(a), Internal Revenue Code of 1954,1 thus entitling petitioner to...

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