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GREENE v. COMMISSIONER

Docket No. 25789-83.

85 T.C. 1024 (1985)

MARTIN I. GREENE AND JUNE A. GREENE, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 24, 1985.

Attorney(s) appearing for the Case

Leonard J. Witman, for the petitioners.

Robert A. Stern, for the respondent.

KÖRNER, Judge:

Respondent determined a deficiency in the petitioners' income tax for the calendar year 1980 in the amount of $16,007.50, together with an addition to tax under section 6653(a)1 in the amount of $800.37. After concessions, the only issue for us to decide in this case is whether petitioner June A. Greene's surrender of an annuity contract which she had with one insurance company, and the immediate reinvestment...

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