STEWART v. COMMISSIONER

Docket No. 1697-78.

43 T.C.M. 1119 (1982)

T.C. Memo. 1982-209

Spencer D. Stewart and Mary Jane Stewart v. Commissioner.

United States Tax Court.

Filed April 21, 1982.


Attorney(s) appearing for the Case

James Powers, 3550 N. Central Ave., Phoenix, Ariz., for the petitioners. Brad S. Ostroff, for the respondent.


Memorandum Findings of Fact and Opinion

KÖRNER, Judge:*

Respondent determined deficiencies in petitioners' Federal income taxes of $210,751.13 for 1966 and $45,444.21 for 1967. After concessions by the parties, the remaining issues for decision are: (1) whether the interest received by petitioners during 1966 from the City of Phoenix is excludible under section 103(a);

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