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ESTATE OF FOSTER v. COMMISSIONER

Docket No. 348-87.

56 T.C.M. 163 (1988)

T.C. Memo. 1988-437

Estate of E. Alvin Foster, Deceased, Eve Johnson, Executrix, and Evelyn Foster v. Commissioner.

United States Tax Court.

Filed September 14, 1988.

Attorney(s) appearing for the Case

William E. Frantz, 3390 Peachtree Rd. N.E., Atlanta, Ga., for the petitioners. Willard N. Timm, Jr., for the respondent.

Memorandum Findings of Fact and Opinion

WILLIAMS, Judge:

The Commissioner determined a deficiency in petitioners' 1982 Federal income tax return of $101,911.44 and additions to tax pursuant to section 66611 in the amount of $10,191.44. The issues we must decide are (1) whether petitioners received taxable dividends in 1982 from their closely held corporations and (2) whether petitioners are liable for additions to tax pursuant...

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