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PURVIS v. COMMISSIONER

Docket No. 16433-81.

46 T.C.M. 593 (1983)

T.C. Memo. 1983-376

Carl A. Purvis v. Commissioner.

United States Tax Court.

Filed June 23, 1983.

Attorney(s) appearing for the Case

C. Geoffrey Vining and Ronald T. Murphy, for the petitioner. Max K. Boyer, for the respondent.

Memorandum Findings of Fact and Opinion

FEATHERSTON, Judge:

Respondent determined a deficiency in the amount of $17,572 in petitioner's Federal income tax for 1977 and an addition to tax under section 6653(a)1 in the amount of $888. The only questions for decision are:

1. Whether petitioner realized income in 1977 from the theft and sale of marijuana and, if so, in what amount; and

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