T.C. Memo. 2005-32
UNITED STATES TAX COURT
INDMAR PRODUCTS CO., INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15428-03. Filed February 23, 2005.
Matthew P. Cavitch and Gerald P. Arnoult, for petitioner.
Kirk S. Chaberski, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge: By notice dated July 3, 2003, respondent
determined deficiencies in, and penalties related to,
petitioner’s 1998, 1999, and 2000 Federal income taxes. After
concessions by respondent, the remaining issues for decision are
whether: (1) The cash transfers to petitioner were loans or
capital investments; and (2) petitioner is liable for section
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