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GARDNER v. COMMISSIONER

Docket No. 9188-73.

35 T.C.M. 1592 (1976)

T.C. Memo. 1976-349

William D. Gardner and Juanita Gardner v. Commissioner.

United States Tax Court.

Filed November 16, 1976.

Attorney(s) appearing for the Case

William E. Scent, 317 West Ninth St., Hopkinsville, Ky., Michael J. Clare and David W. Gray, for the petitioners. Jack A. Joynt, for the respondent.

Memorandum Findings of Fact and Opinion

SCOTT, Judge:

Respondent determined a deficiency in the Federal income tax of petitioners William D. Gardner and Juanita Gardner in the amount of $10,922.15 for the calendar year 1970.

The issues for decision are (1) whether amounts paid in 1970 by the corporation of which one of petitioners was controlling stockholder were payments in satisfaction of an obligation...

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