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NATIONAL OIL COMPANY v. COMMISSIONER

Docket No. 28073-81.

52 T.C.M. 1223 (1986)

T.C. Memo. 1986-596

National Oil Company v. Commissioner.

United States Tax Court.

Filed December 23, 1986.

Attorney(s) appearing for the Case

Thomas C. Triplett, 220 W. Douglas St., Wichita, Kan. for the petitioner. Mark H. Howard, for the respondent.

Memorandum Findings of Fact and Opinion

WHITAKER, Judge:

Respondent determined a deficiency in petitioner's income tax in the amount of $144,348.49 for the calendar year ended December 31, 1977. After concessions the issues for decision are:

(1) Whether during the year 1977 petitioner received in exchange for services a capital interest in the limited partnership known as National Oil Program (NOP-77), and if so, what is the value of said interest...

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