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LUDWIG v. COMMISSIONER

Docket No. 5764-75.

68 T.C. 979 (1977)

DANIEL K. LUDWIG AND GERTRUDE V. LUDWIG, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 29, 1977.

Attorney(s) appearing for the Case

Richard G. Cohen, Gary I. Fritzhand, and R. Palmer Baker, Jr., for the petitioners.

Larry Kars, for the respondent.

FEATHERSTON, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for 1963 in the amount of $4,438,086.75. After various concessions by the parties, the sole issue remaining for decision is whether a controlled foreign corporation wholly owned by petitioner Daniel K. Ludwig was a guarantor, within the meaning of section 956(c),1 of petitioner's obligations to a group of lending banks, with the result that...

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