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GOLDSTEIN v. COMMISSIONER

Docket Nos. 11158-77, 11170-77.

40 T.C.M. 752 (1980)

T.C. Memo. 1980-273

Alfred R. and Ann L. Goldstein v. Commissioner. Barbara L. Goldsmith v. Commissioner.

United States Tax Court.

Filed July 28, 1980.

Attorney(s) appearing for the Case

Hirschell E. Levine, Lawrence S. Albert, 250 Park Ave., New York, N.Y., for the petitioners. Barry C. Feldman, Vincent R. Barrella, for the respondent.

Memorandum Findings of Fact and Opinion

HALL, Judge:

Respondent determined deficiencies in income tax as follows:

     Petitioner(s)                Year    Deficiency

  Alfred R. and Ann L. Goldstein  1972     $30,798
   (Docket No. 11158-77)
  Barbara L. Goldsmith .......... 1972      33,039
    (Docket No. 11170-77)

The sole issue for decision is whether interest-free "loans" made to trusts created for the benefit of petitioners...

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