Jordanos', Inc., Madeline F. Jordano, Howard H. King and Delfina I. King, Helen M. Jordano v. Commissioner of Internal Revenue
Opinion
Opinion
This case is before us pursuant to section 7482 of the Internal Revenue Code of 1954, which authorizes our review of de cisions of the Tax Court of the United States. Several taxpayers have petitioned for review of four consolidated Tax Court decisions in favor of the Commissioner of Internal Revenue. The decisions, which concern the petitioners’ income tax liability for the years 1958 to 1961, inclusive, turn on a finding that payments made by the corporate petitioner to three of the individual petitioners represented dividends, and not gifts or compensatory pensions.
We think that that finding is not clearly erroneous, and we therefore must affirm the Tax Court’s decision. See Commissioner of Internal Revenue v. Duberstein, 363 U.S. 278, 289 , 80 S.Ct. 1190 , 4 L.Ed.2d 1218 (1960). That court’s Memorandum Findings of Fact and Opinion, T.C. Memo., 1966-218, filed September 30, 1966, and not officially reported, is attached as an appendix to this opinion.
Affirmed.
APPENDIX
T. C. Memo. 1966-218
TAX COURT OF THE UNITED STATES
Jordanos’, Inc., et al., Petitioners, v. Commissioner of Internal Revenue, Respondent.
Docket Nos. 5316-64, 5317-64, 5318-64, 5319-64,