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MADDRIX v. COMMISSIONER

Docket No. 10979-81.

83 T.C. 613 (1984)

JAMES MADDRIX AND ALICE MADDRIX, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 22, 1984.

Attorney(s) appearing for the Case

Elliot I. Miller and Richard S. Kastenbaum, for the petitioners.

Theodore J. Kletnick and Kendall C. Jones, for the respondent.

OPINION

STERRETT, Judge:

In a notice of deficiency dated March 9, 1981, respondent determined a deficiency of $67,900.51 in petitioners' 1977 Federal income tax.

Respondent has filed a motion for partial summary judgment pursuant to Rule 121, Tax Court Rules of Practice and Procedure.1 The issues raised in respondent's motion are (1) whether certain amounts paid2 by petitioners in 1977...

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