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LESSINGER v. COMMISSIONER

Docket No. 24103-81.

85 T.C. 824 (1985)

SOL LESSINGER AND EDITH LESSINGER, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed November 20, 1985.

Attorney(s) appearing for the Case

Bruno Schachner, for the petitioners.

William Gross, Arnold Gould, and Robert L. Schneps for the respondent.

CLAPP, Judge:

Respondent determined deficiencies in petitioners' Federal income tax in the amounts of $114,147.30 and $1,427.50 for the taxable years 1977 and 1978, respectively.

After concessions, the issues remaining for decision are: (1) Whether petitioner Sol Lessinger should recognize gain of $251,014, in the taxable year 1977 pursuant to section 357(c);1 and (2) whether petitioner...

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