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ZETTNER v. COMMISSIONER

Docket No. 24276-83.

48 T.C.M. 981 (1984)

T.C. Memo. 1984-463

Charles F. Zettner and Judy J. Zettner v. Commissioner.

United States Tax Court.

Filed August 29, 1984.

Attorney(s) appearing for the Case

Charles F. Zettner, pro se, Henderson, Nev. Benjamin C. Sanchez, A. Chris Zimmerman and S. Clay Freed, for the respondent.

Memorandum Findings of Fact and Opinion

DRENNEN, Judge:

Respondent determined a deficiency of $5,716 in and an addition of $285.80 to petitioners' 1981 Federal income tax. The issues for decision are: (1) whether petitioners are entitled to deduct a "factors discount" in the amount of $22,895.05 in connection with a purported assignment of the personal services of Charles F. Zettner to a trust, and (2) whether petitioners are liable for the addition to tax...

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