SIEWERT v. COMMISSIONER

Docket No. 169-77.

72 T.C. 326 (1979)

COURTNEY L. SIEWERT, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 14, 1979.


Attorney(s) appearing for the Case

Clarence P. Brazill, Jr., and John A. Freels, for the petitioner.

Deborah A. Butler, for the respondent.


FEATHERSTON, Judge:

Respondent determined a deficiency in the amount of $2,976.28 in petitioner's Federal income tax for 1972. Petitioner concedes the adjustments determined by respondent in the notice of deficiency. He claims, however, a refund in the amount of $21,288.07 for 1972, raising for decision the following issues:

(1) Whether the division of property between petitioner Courtney L. Siewert and Helen Siewert, husband and wife, under a property...

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