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MARKOSIAN v. COMMISSIONER

Docket No. 10775-77.

73 T.C. 1235 (1980)

LOUIS MARKOSIAN AND JOAN P. MARKOSIAN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 31, 1980.

Attorney(s) appearing for the Case

Paul T. Wright, for the petitioners.

Richard A. Jones, for the respondent.

DRENNEN, Judge:

Respondent has determined a deficiency of $10,312 in petitioners' income tax for the taxable year 1975. The issues for our decision are:

(1) Whether a trust purportedly created by petitioners is entitled to be recognized as an entity separate and distinct from the taxpayers;

(2) Alternatively, whether the taxpayers are to be treated as owners of the trust under sections 671 through 677, I.R.C. 1954;1

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