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PEARSALL v. COMMISSIONER

Docket No. 3524-73.

36 T.C.M. 956 (1977)

T.C. Memo. 1977-230

John W. Pearsall and Laila W. Pearsall v. Commissioner.

United States Tax Court.

Filed July 25, 1977.

Attorney(s) appearing for the Case

John W. Pearsall, III, 320 Mutual Bldg., Richmond, Va., for the petitioners. Robert T. Hollohan, for the respondent.

Memorandum Findings of Fact and Opinion

STERRETT, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes for the calendar years as follows:

  Year                    Deficiency

  1969 .................. $ 5,305.42
  1970 ..................   3,154.51
  1971 ..................  13,580.63

Due to concessions by respondent, the sole issue for our decision concerns the determination of the fair market value...

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