GRAY v. COMMISSIONER

Docket No. 5402-77.

71 T.C. 95 (1978)

ARTHUR J. GRAY AND ESTHER GRAY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 30, 1978.


Attorney(s) appearing for the Case

James R. Mayo, for the petitioners.

Gordon W. Cook, for the respondent.


QUEALY, Judge:

Respondent determined a deficiency of $13,733 in petitioners' Federal income taxes for the 1973 calendar taxable year. Because of the concessions made by the parties, the only issue remaining for decision is whether payments received by petitioners upon the termination of certain lease and management contracts shall be considered as amounts received in an exchange for such leases within the meaning of section 1241.1

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