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KRAPF v. COMMISSIONER

Docket Nos. 10809-75, 9261-76.

37 T.C.M. 594 (1978)

T.C. Memo. 1978-138

Frederic G. Krapf, Jr., and June B. Krapf v. Commissioner.

United States Tax Court.

Filed April 11, 1978.

Attorney(s) appearing for the Case

Robert E. Schlusser, Bank of Delaware Bldg., 300 Delaware Ave., Wilmington, Del. 19899, for the petitioners. Frank Coyne and Carolyn M. Parr, for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

Respondent determined deficiencies of $132,381 and $73,633 in petitioners' Federal income tax for the years 1970 and 1971, respectively. The issues for our decision are:

(1) Whether amounts disbursed by Frederic G. Krapf Construction Company during 1970 and 1971 for the construction of a yacht constitute taxable dividends to Frederic G. Krapf, Jr., its president and controlling shareholder.<...

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