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DOWNER v. COMMISSIONER

Docket No. 2082-65.

48 T.C. 86 (1967)

J.K. DOWNER AND EDITH DOWNER, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 27, 1967.

Attorney(s) appearing for the Case

Jerry D. Luptak and Basil M. Briggs, for the petitioners.

Charles R. Abbott, for the respondent.

TANNENWALD, Judge:

Respondent determined a deficiency in petitioners' income tax for the taxable year 1961 in the amount of $36,365.31. Petitioners have claimed an overpayment of income taxes for 1961 in an unspecified amount. After concession by petitioners of certain issues, there remains for us to decide whether petitioners are entitled to a deduction in 1961 in respect of stock transferred in that year and, if so, the nature and amount of such deduction...

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