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CARROLL v. COMMISSIONER

Docket No. 1221-75.

37 T.C.M. 736 (1978)

T.C. Memo. 1978-173

Preston W. Carroll and Dorothy Carroll v. Commissioner.

United States Tax Court.

Filed May 10, 1978.

Attorney(s) appearing for the Case

Ervin M. Entrekin, First American Center, Nashville, Tenn., for the petitioners. John B. Harper, for the respondent.

Memorandum Findings of Fact and Opinion

TANNENWALD, Judge:

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

  Year             Deficiency

  1969 .........   $293,044.94
  1970 .........    406,237.79
  1971 .........    432,503.02

The issues remaining for decision are: (1) whether payments made to a corporation wholly owned by Preston W. Carroll...

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