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PRICE v. COMMISSIONER

Docket No. 19073-80.

46 T.C.M. 1607 (1983)

T.C. Memo. 1983-617

Samuel L. Price and Carmen L. Price v. Commissioner.

United States Tax Court.

Filed September 28, 1983.

Attorney(s) appearing for the Case

Gary R. Pearson, 620 N. 48th St., Lincoln, Neb., for the petitioners. J. Anthony Hoefer, for the respondent.

Memorandum Findings of Fact and Opinion

PARKER, Judge:

Respondent determined a deficiency of $10,019 in petitioners' Federal income tax for the taxable year 1976. The issue is whether a certain distribution of money to petitioners by their electing small business corporation satisfies the requirements of section 1375(f),1 so as to be treated as the receipt of previously taxed "undistributed taxable income" rather than as taxable...

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