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NICOLAISEN v. COMMISSIONER

Docket No. 12033-81.

49 T.C.M. 977 (1985)

T.C. Memo. 1985-120

Frederick C. and Linda S. Nicolaisen v. Commissioner.

United States Tax Court.

Filed March 20, 1985.

Attorney(s) appearing for the Case

Anthony F. Mercurio, for the petitioners. David W. Johnson, for the respondent.

Memorandum Opinion

FAY, Judge:*

With respect to petitioners' 1977 Federal income tax, respondent determined a deficiency of $5,813.00 and an addition to tax of $290.65 under section 6653 (a)1,2. After concessions by both parties, the remaining issues are (1) whether certain amounts paid to petitioners by the Panama Canal Company in 1977 are excludible from gross income...

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