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COOK v. COMMISSIONER

Docket No. 6463-80.

80 T.C. 512 (1983)

CHARLES D. COOK AND CAROLYN C. COOK, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 8, 1983.

Attorney(s) appearing for the Case

Julian S. Greenspun, for the petitioners.

Robert E. Marum, for the respondent.

DRENNEN, Judge:

Respondent determined a deficiency in, and an addition to, petitioners' 1976 Federal income tax in the amounts of $384,437 and $19,222, respectively. The issues for decision are (1) whether the transfer of appreciated stock and real properties by Charles D. Cook to his former wife pursuant to a divorce decree was a taxable transaction, and (2) whether petitioners are liable for an addition to tax pursuant to section 6653(a).

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