LEMERY v. COMMISSIONER

Docket No. 2306-67.

54 T.C. 480 (1970)

DOUGLAS J. LEMERY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 12, 1970.


Attorney(s) appearing for the Case

Roger E. Lageschulte, for the petitioner.

Stephen E. Silver, for the respondent.


FORRESTER, Judge:

Respondent determined deficiencies in income tax and additions thereto as follows:

Year                             Deficiency   Sec. 6653(a)

1964 ---------------------------  $34,985.52    $1,749.28

The issues to be decided herein are: (1) Whether petitioner's long-term capital gains from the sale of stock are exempt from income tax under article VIII of the Income Tax Convention and Protocol...

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