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TEMPLETON v. COMMISSIONER

Docket No. 216-74.

66 T.C. 509 (1976)

FRANK G. TEMPLETON AND HELEN M. TEMPLETON, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 21, 1976.

Attorney(s) appearing for the Case

J. Randall Groves, Richard E. Thigpen, Jr., W. Pinkney Herbert, Jr., and J. Michael Booe, for the petitioners.

Eric B. Jorgensen, for the respondent.

OPINION

SIMPSON, Judge:

The Commissioner determined the following deficiencies in the petitioners' Federal income tax:

        Year                   Deficiency

        1969---------------   $76,399.36
        1970---------------     4,531.79
        1971---------------     2,348.27

The issue to be decided is whether, under section 1033 of the Internal Revenue Code of 1954,1 the...

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