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BOWMAN v. COMMISSIONER

Docket No. 6078-95.

73 T.C.M. 1859 (1997)

T.C. Memo. 1997-52

Norton M. Bowman v. Commissioner.

United States Tax Court.

Filed January 28, 1997.

Attorney(s) appearing for the Case

Herman C. Daniel III, Richmond, Va., for the petitioner. Deborah C. Stanley, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

WELLS, Judge:

Respondent determined a deficiency of $37,684 in petitioner's 1988 Federal income tax. The issues we must decide are: (1) Whether a distribution received by petitioner during 1988 constituted a repayment of a loan or a dividend and (2) the amount received by petitioner.1

FINDINGS OF FACT

Some of the facts have been stipulated for trial pursuant to Rule 91...

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