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MAGNESON v. COMMISSIONER

Docket No. 28473-81.

81 T.C. 767 (1983)

NORMAN J. MAGNESON AND BEVERLY G. MAGNESON, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 20, 1983.

Attorney(s) appearing for the Case

Thomas W. Bettles, for the petitioners.

Kevin M. Bagley, for the respondent.

OPINION

GOFFE, Judge:

The Commissioner determined a deficiency in petitioners' Federal income tax for the taxable year 1977 in the amount of $19,563. The sole issue for decision is whether the exchange of petitioners' fee simple interest in real property for a 10-percent undivided interest in other real property followed immediately by contribution of the 10-percent interest to a partnership for a 10-percent...

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