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DENISON v. COMMISSIONER

Docket Nos. 5485-74, 5565-74.

36 T.C.M. 1759 (1977)

T.C. Memo. 1977-430

Robert J. Denison v. Commissioner. George F. Baker, III v. Commissioner.

United States Tax Court.

Filed December 22, 1977.

Attorney(s) appearing for the Case

Emil Sebetic, Sidney O. Friedman, and Michael A. Varet, 30 Broad St., New York, N.Y., for petitioners. Michael A. Menillo, for the respondent.

Memorandum Findings of Fact and Opinion

TANNENWALD, Judge:

Respondent determined the following deficiencies in petitioners' Federal income taxes:

  Docket No.                1970         1971

   5485-74 ............. $ 87,778.00    $293.00
   5565-74 .............  137,708.00      -0-

Petitioner in docket No. 5485-74 having conceded the deficiency for 1971, the issues remaining for our decision are:

(1) Whether payments...

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