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GRAY v. COMMISSIONER

Docket Nos. 2376-68-2381-68.

71 T.C. 719 (1979)

JOHN D. GRAY AND ELIZABETH N. GRAY, ET AL., PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 1, 1979.

Attorney(s) appearing for the Case

Michael Waris, Jr., Robert J. Cunningham, and Donald Baker, for the petitioners.

John D. Picco and Gary R. DeFrang, for the respondent.

OPINION

STERRETT, Judge:

These cases are before us on remand from the Ninth Circuit following that court's decision in Gray v. Commissioner, 561 F.2d 753 (9th Cir. 1977). A controversy has arisen between the parties with respect to the amount of undistributed foreign personal holding company income taxable to petitioners as a result of the transaction herein and the taxable year in which petitioners must take...

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