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VIRGIL v. COMMISSIONER

Docket No. 16384-81.

47 T.C.M. 692 (1983)

T.C. Memo. 1983-757

E.M. Gammelgard Virgil v. Commissioner.

United States Tax Court.

Filed December 19, 1983.

Attorney(s) appearing for the Case

James K. Norman, 1409 Lincoln Way, Auburn, Calif., for the petitioner. Theodore Garelis, for the respondent.

Memorandum Findings of Fact and Opinion

FORRESTER, Judge:

Respondent determined a deficiency of $6,778 in petitioner's income tax for 1977. At issue is whether partnership income reported by two children of petitioner should be reallocated to petitioner.

Findings of Fact

Some of the facts have been stipulated and are so found.

Petitioner resided in California when the petition in...

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