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ESTATE OF LIECHTUNG v. COMMISSIONER

Docket No. 8720-78.

40 T.C.M. 1118 (1980)

T.C. Memo. 1980-352

Estate of Benjamin Liechtung, Deceased, Herbert Liechtung and Harriett Schechter, Administrators and Sadie Liechtung v. Commissioner.

United States Tax Court.

Filed September 2, 1980.

Attorney(s) appearing for the Case

Steven Kamerman, 500 Fifth Ave., New York, N.Y., for the petitioners. Barry C. Feldman and Theodore M. David, for the respondent.

Memorandum Opinion

TANNENWALD, Judge:

Respondent determined deficiencies in petitioners' income tax of $8,255 in 1974 and $6,477 in 1975. The sole issue presented is whether Benjamin Liechtung realized taxable income from the interest-free use of funds borrowed from a corporation of which he was the president and sole shareholder.

This case was submitted fully stipulated pursuant to Rule 122, Tax Court Rules of Practice and Procedure.

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