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PORTERMAIN v. COMMISSIONER

Docket No. 23759-84.

58 T.C.M. 293 (1989)

T.C. Memo. 1989-539

Neill W. Portermain and Florence M. Portermain v. Commissioner.

United States Tax Court.

Filed September 28, 1989.

Attorney(s) appearing for the Case

C.F. Allison, Jr., 2200 Ross Ave., Dallas, Tex., and William B. Steele III, for the petitioners. John S. Repsis and James F. Prothro, for the respondent.

Memorandum Findings of Fact and Opinion

PARR, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for the calendar year 1980 of $263,556, and an addition to tax under section 6653(a)1 of $13,178.

Petitioners concede receipt of constructive dividend income of $15,306 in 1980 from Mr. Portermain's wholly-owned corporation, United Nebraska Investors, Inc. Petitioners paid the income tax attributable...

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