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PULLIAM v. COMMISSIONER

Docket No. 12923-95.

73 T.C.M. 3052 (1997)

T.C. Memo. 1997-274

Clark D. and Janis L. Pulliam v. Commissioner.

United States Tax Court.

Filed June 17, 1997.

Attorney(s) appearing for the Case

Robert J. Schuckit and Richard O. Kissell II, Indianapolis, Ind., for the petitioners. Russell D. Pinkerton, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

DAWSON, Judge:1

Respondent determined a deficiency of $245,732 in petitioners' Federal income tax for 1992, and an accuracy-related penalty of $49,146 under section 6662(a)2 and 6662(b)(2) for a substantial understatement of income tax.

The principal issue for decision is whether the distribution by Pulliam Funeral Homes, P.C. (Homes) to petitioner Clark...

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