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THOR ENERGY RESOURCES AND SUBSIDIARIES v. COMMISSIONER

Docket No. 23161-92.

70 T.C.M. 1057 (1995)

T.C. Memo. 1995-505

Thor Energy Resources and Subsidiaries v. Commissioner.

United States Tax Court.

Filed October 23, 1995.

Attorney(s) appearing for the Case

Salvador E. Rodriguez, Houston, Tex., for the petitioner. Dennis M. Kelly, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

CLAPP, Judge:

Respondent determined a deficiency in petitioner's Federal corporate income tax for the year ended January 31, 1989, in the amount of $25,633.

After concessions by the parties, the issue for decision is whether Shefferman & Bigelson Co. (S&B) distributed a dividend to Thor Energy Resources, Inc. (Thor), in the amount of $1,245,880.36, and if so, the effect of that distribution on Thor...

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