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BORKOWSKI v. COMMISSIONER

Docket No. 14957-79.

43 T.C.M. 593 (1982)

T.C. Memo. 1982-87

M. John Borkowski and Lorraine Borkowski v. Commissioner.

United States Tax Court.

Filed February 18, 1982.

Attorney(s) appearing for the Case

Robert E. Johnson, One Indiana Square, Indianapolis, Ind., for the petitioners. Michael J. Rusnak, for the respondent.

Memorandum Findings of Fact and Opinion

SIMPSON, Judge:

The Commissioner determined deficiencies in the petitioners' Federal income taxes of $8,418.16 for 1976 and $8,890.48 for 1977. After concessions by the parties, the issues for decision are: (1) Whether, when Dr. Borkowski transferred some of the stock in an electing small business corporation to his children, they became the beneficial owners of such stock so that Dr. Borkowski was not required to...

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