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WACKER v. COMMISSIONER

Docket No. 11298-77.

40 T.C.M. 1009 (1980)

T.C. Memo. 1980-324

Orville C. Wacker and Pearl Wacker v. Commissioner.

United States Tax Court.

Filed August 19, 1980.

Attorney(s) appearing for the Case

Lee M. Galloway, 1065 J.D., Sacramento, Calif., for the petitioners. Gerald J. Beaudoin, for the respondent.

Memorandum Opinion

SCOTT, Judge:

Respondent determined deficiencies in the joint Federal income tax of Orville C. Wacker and Pearl Wacker in the amounts of $119,914.64 and $42 for calendar years 1974 and 1975, respectively.

Some of the issues raised by the pleadings have been disposed of by agreement of the parties, leaving for decision:

(1) Whether a 1974 agreement between petitioners, as the sellers of Royal Villa Garden Apartments, and...

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