MICHOT v. COMMISSIONER

Docket Nos. 10474-79, 2257-80.

43 T.C.M. 792 (1982)

T.C. Memo. 1982-128

Louis J. and Patricia A. Michot v. Commissioner.

United States Tax Court.

Filed March 16, 1982.


Attorney(s) appearing for the Case

F. Kelleher Riess, 821 Gravier St., New Orleans, La., William T. Steen, Pan American Life Ins. Co., New Orleans, La. and James Parkerson Roy, for the petitioners in docket No. 10474-79. F. Kelleher Riess, for the petitioners in docket No. 2257-80. Deborah R. Jaffe, for the respondent.


Memorandum Findings of Fact and Opinion

FAY, Judge:

Respondent determined the following deficiencies in petitioners' Federal income tax:

  Year                 Deficiency

  1974 ..............   $40,511
  1975 ..............    21,361
  1976 ..............     3,582
  1977 ..............     9,837

The issue for decision is whether amounts received by petitioner Louis J. Michot upon termination of franchising agreements are taxable...

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