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MARTIN v. COMMISSIONER

Docket No. 6854-77.

39 T.C.M. 531 (1979)

T.C. Memo. 1979-469

William G. and Martha C. Martin v. Commissioner.

United States Tax Court.

Filed November 26, 1979.

Attorney(s) appearing for the Case

Kirk R. Manning, 1800 First Nat'l Bank Bldg., Fort Worth, Tex., for the petitioners. Charles L. McReynolds, for the respondent.

Memorandum Findings of Fact and Opinion

DRENNEN, Judge:

Respondent has determined the following deficiencies in income tax for the following years:

  1973 .................. $ 3,982.20
  1974 ..................  15,759.98

After concessions, the only issue remaining for our resolution is:

Whether petitioners are in receipt of income during the tax years in issue by virtue of receiving certain interest-free loans, directly...

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