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GEHL v. COMMISSIONER

Docket No. 10541-92.

102 T.C. 784 (1994)

JAMES J. AND LAURA GEHL, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 22, 1994.

Attorney(s) appearing for the Case

David Hughes, for petitioners.

Jeffrey A. Schlei, for respondent.

OPINION

TANNENWALD, Judge:

Respondent determined deficiencies in petitioners' Federal income tax for the years 1988 and 1989 in the amounts of $6,887.00 and $13,643.00, respectively. The sole issue is the proper treatment of the excess of the fair market value over basis of property, transferred by petitioners to a creditor in partial satisfaction of a debt.

All the facts have been stipulated and...

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