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PRUSAK v. COMMISSIONER

Docket Nos. 2465-76, 6225-77.

38 T.C.M. 518 (1979)

T.C. Memo. 1979-112

John J. Prusak v. Commissioner. Joseph A. Prusak v. Commissioner.

United States Tax Court.

Filed March 27, 1979.

Attorney(s) appearing for the Case

Raymond M. Pezzo, 272 Mill St., Poughkeepsie, N.Y. for the petitioners. Jack H. Klinghoffer, for the respondent.

Memorandum Opinion

TANNENWALD, Judge:

In these consolidated cases, respondent determined deficiencies in petitioners' Federal income tax for the calendar year 1973 in the following amounts:

  Docket No. 2465-76 ............  $5,751.63
  Docket No. 6225-77 ............   3,562.88

The sole issue is whether petitioners' stock in Tarry Hope, Inc., was "section 1244 stock,"1 with the result that petitioners...

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