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PEOPLES LOAN & TRUST CO. v. COMMISSIONER

Docket Nos. 30402-84, 30420-84.

58 T.C.M. 227 (1989)

T.C. Memo. 1989-524

Peoples Loan & Trust Co., as Possessor of Certain Cash v. Commissioner. Leon E. Hendrickson, as Possessor of Certain Cash v. Commissioner.

United States Tax Court.

Filed September 26, 1989.

Attorney(s) appearing for the Case

Robert E. Johnson and Marc A. Hertzner, One Indiana Square, Indianapolis, Ind., for the petitioners. Rodney J. Bartlett, for the respondent.

Memorandum Findings of Fact and Opinion

KÖRNER, Judge:

Respondent determined a deficiency in income tax of $113,250.00 for taxable year 1983 against Peoples Loan & Trust Co. ("Peoples"), as possessor of certain cash. He also determined a deficiency of $1,834,500.25 for taxable year 1983 against Leon E. Hendrickson, as possessor of certain cash. After trial, this Court filed its Findings of Fact and Opinion in these consolidated cases on October...

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