KISSKA v. COMMISSIONER

Docket No. 2258-80.

42 T.C.M. 1651 (1981)

T.C. Memo. 1981-655

Lester Kisska and Virginia B. Kisska v. Commissioner.

United States Tax Court.

Filed November 10, 1981.


Attorney(s) appearing for the Case

Mitchell J. Olejko, C. James Judson, and Richard E. Cassard, 4200 Seattle First National Bank Bldg., Seattle, Wash., for the petitioners. Jeannette A. Cyphers, for the respondent.


Memorandum Findings of Fact and Opinion

FEATHERSTON, Judge:

Respondent determined a deficiency in the amount of $4,676 in petitioners' Federal income tax for 1977. The issues for decision are:

1. Whether a payment by petitioners for the release from liability on a promissory note which arose from the prior purchase of certain property constitutes a reduction of the capital gain recognized on the sale of that property, as contended by respondent,...

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