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HOLBROOK v. COMMISSIONER

Docket No. 2475-66.

54 T.C. 1617 (1970)

FINLEY W. HOLBROOK AND FAITH HOLBROOK, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 20, 1970.

Attorney(s) appearing for the Case

Wm. Monroe Kerr, for the petitioners.

John W. Dierker, for the respondent.

OPINION

TANNENWALD, Judge:

Respondent determined deficiencies of $3,263.45 and $4,314.79 in petitioners' income taxes for the years 1963 and 1964, respectively. The only issue remaining for our determination is whether petitioners constructively received taxable income of $7,579.51 and $3,356.07 in the years 1963 and 1964 derived from an oil and gas production payment made to a third party because petitioner Finley W. Holbrook guaranteed the payment...

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