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 sectionPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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