Proctor v. Commissioner
United States Tax Court
Petitioners Joseph and Shirley Proctor owned all of the stock in petitioner Chattanooga Products while Joseph Proctor (Proctor) individually owned all of the stock in petitioner R & D. 1. Held, the Proctors failed to prove that unexplained bank deposits in 1972, 1973 and 1976 did not represent unreported income as determined by respondent. 2. Held, charitable contribution deductions under sec. 170(a)(1), I.R.C. 1954, for the Proctors' 1972, 1973 and 1976 tax years…
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Petitioners Joseph and Shirley Proctor owned all of the stock in petitioner Chattanooga Products while Joseph Proctor (Proctor) individually owned all of the stock in petitioner R & D. 1. Held, the Proctors failed to prove that unexplained bank deposits in 1972, 1973 and 1976 did not represent unreported income as determined by respondent. 2. Held, charitable contribution deductions under sec. 170(a)(1), I.R.C. 1954, for the Proctors' 1972, 1973 and 1976 tax years determined. 3. Held, payments by Proctor to Chattanooga Products and R & D during 1976 constituted interest deductible under sec.…
1Opinion of the Court
JOSEPH E. PROCTOR and SHIRLEY I. PROCTOR, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Proctor v. Commissioner
Docket Nos. 11063-78, 11064-78, 11065-78.
United States Tax Court
T.C. Memo 1981-436; 1981 Tax Ct. Memo LEXIS 307; 42 T.C.M. (CCH) 725; T.C.M. (RIA) 81436;
August 17, 1981.
Petitioners Joseph and Shirley Proctor owned all of the stock in petitioner Chattanooga Products while Joseph Proctor (Proctor) individually owned all of the stock in petitioner R & D.
1. Held, the Proctors failed to prove that unexplained bank deposits in 1972, 1973 and 1976 did not represent…
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