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SMITH v. COMMISSIONER

Docket No. 25830-81.

48 T.C.M. 1420 (1984)

T.C. Memo. 1984-553

Robert Kemper Smith, Sr. v. Commissioner.

United States Tax Court.

Filed October 17, 1984.

Attorney(s) appearing for the Case

Robert Kemper Smith, Sr., pro se, El Cerrito, Calif. Theodore Garelis, for the respondent.

Memorandum Findings of Facts and Opinion

GOFFE, Judge:

The Commissioner determined a deficiency in petitioner's1 Federal income tax for the taxable year 1978 in the amount of $831. The only issue for decision is whether petitioner has satisfied the requirements for exclusion of a portion of his disability income under section 105(d).2

Findings of Fact

Some of the facts have been...

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