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GILDAY v. COMMISSIONER

Docket No. 22005-80.

43 T.C.M. 1295 (1982)

T.C. Memo. 1982-242

Donald S. Gilday and Patsy L. Gilday v. Commissioner.

United States Tax Court.

Filed May 3, 1982.

Attorney(s) appearing for the Case

Michael H. Singer and Mark Segal, 520 South 4th St., Las Vegas, Nev., for the petitioners. A. Chris Zimmermann, for the respondent.

Memorandum Findings of Fact and Opinion

FAY, Judge:

Respondent determined a deficiency of $24,498 in petitioners' Federal income tax for 1976. At issue is whether there existed a corporate debt to petitioners within the meaning of section 1374(c)(2)(B).1

Findings of Fact

Some facts have been stipulated and are found accordingly.

Petitioners, Donald S. Gilday and Patsy L. Gilday, resided in Las Vegas...

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