JACOBS v. COMMISSIONER

Docket No. 3255-71.

33 T.C.M. 848 (1974)

T.C. Memo. 1974-196

Julian E. Jacobs and Jane S. Jacobs v. Commissioner.

United States Tax Court.

Filed July 30, 1974.


Attorney(s) appearing for the Case

Elton B. Taylor, 723 S. Sharon-Amith Road, Charlotte, N.C., for the petitioners. Wright Tisdale, Jr., for the respondent.


Memorandum Findings of Fact and Opinion

IRWIN, Judge:

Respondent determined deficiencies in petitioners' income taxes for the calendar years 1967 and 1968 in the amounts of $1,247.50 and $3,645.25, respectively. The only issue presented is whether monthly payments received by petitioner in liquidation of his interest in a partnership were ordinary income or capital gain.

Findings of Fact

Some of the facts have been stipulated and they are...

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