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ESTATE OF RIPSON v. COMMISSIONER

Docket No. 10771-77.

39 T.C.M. 224 (1979)

T.C. Memo. 1979-394

Estate of Sheldon Ripson, Deceased, Dean Ripson and Edna Ripson, Co-Executors, and Edna Ripson v. Commissioner.

United States Tax Court.

Filed September 24, 1979.

Attorney(s) appearing for the Case

Alan D. Slattery, Penny Berger, William F. Wright and David A. Ludtke, 1201 J St., Lincoln, Neb., for the petitioners. J. Anthony Hoefer, for the respondent.

Memorandum Findings of Fact and Opinion

SCOTT, Judge:

Respondent determined a deficiency in the Federal income tax of the Estate of Sheldon Ripson, deceased, Dean Ripson and Edna Ripson, co-executors, and Edna Ripson, for the taxable year 1974 in the amount of $15,294.

The issues for decision are: (1) Whether payments in satisfaction of debts owed by a corporation but guaranteed and paid by its sole shareholder and his wife were contributions to...

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