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  5. 41 T.C.M. 690 (1981)
 

KLUGE v. COMMISSIONER

Docket No. 5560-78.

41 T.C.M. 690 (1981)

T.C. Memo. 1981-5

John W. Kluge and Yolanda Kluge v. Commissioner.

United States Tax Court.

Filed January 5, 1981.

Attorney(s) appearing for the Case

Thomas A. O'Neil, James R. Murphy, James E. Rodgers, and John C. Smuck, for the petitioners. Joyce H. Errecart, for the respondent.

Memorandum Findings of Fact and Opinion

TIETJENS, Judge:

Respondent determined a deficiency of $131,530 in petitioners' Federal income tax for 1974.1 The issue for our determination is whether petitioner John W. Kluge received a dividend of $189,096 from his wholly owned corporation.

Findings of Fact

Some of the facts have been stipulated and are so found. The stipulation and attached exhibits are incorporated...

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