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PITTS v. COMMISSIONER

Docket No. 8819-75.

37 T.C.M. 1849 (1978)

T.C. Memo. 1978-469

Thurman L. Pitts and Ann B. Pitts v. Commissioner.

United States Tax Court.

Filed November 27, 1978.

Attorney(s) appearing for the Case

Lauch M. Magruder, Jr., 1800 Deposit Guaranty Plaza, Jackson, Miss., for the petitioners. Thomas R. Thomas, for the respondent.

Memorandum Findings of Fact and Opinion

IRWIN, Judge:

Respondent determined a deficiency of $19,042.95 in petitioners' income tax for 1969.

The issues to be decided are as follows: (1) Whether certain debits made by petitioners' wholly-owned corporation to an account payable to petitioner Thurman L. Pitts are distributions of property or loan repayments; (2) whether distributions of property by the corporation to petitioners constitute dividends...

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