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DOUGHERTY v. COMMISSIONER

Docket No. 2400-69.

60 T.C. 917 (1973)

ALBERT L. AND CHARLOTTE K. DOUGHERTY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 18, 1973.

Attorney(s) appearing for the Case

Thomas J. Donnelly, Jr., and John A. Hazelwood, for the petitioners.

Robert T. Hollohan, for the respondent.

TANNENWALD, Judge:*

Respondent determined a deficiency of $412,241.87 in petitioners' income tax for 1963. Petitioners contest the inclusion in their gross income for that year of any amount under section 951(a)(1)(B).1

FINDINGS OF FACT

Some of the facts have been stipulated. The stipulation of facts and attached exhibits are incorporated herein by this reference.

Petitioners...

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