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DePASQUALE v. COMMISSIONER

Docket No. 4080-73.

34 T.C.M. 841 (1975)

T.C. Memo. 1975-196

Louis P. De Pasquale and Jimmie Ann De Pasquale v. Commissioner.

United States Tax Court.

Filed June 23, 1975.

Attorney(s) appearing for the Case

Leonard Bailin, 299 Broadway, New York, N.Y., for the petitioners. Michael A. Menillo, for the respondent.

Memorandum Findings of Fact and Opinion

FEATHERSTON, Judge:

Respondent determined the following deficiencies in petitioners' Federal income tax:

  Taxable Year        Deficiency

      1967 .......... $ 2,815.00
      1968 ..........  44,017.00
      1970 ..........   3,406.49

The issues to be decided are as follows:

1. Whether certain advances made by petitioners to two corporations were loans or contributions to capital...

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