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GRAVES v. COMMISSIONER

Docket No. 10318-85.

88 T.C. 28 (1987)

CHARLES GRAVES AND DOROTHY GRAVES, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 7, 1987.

Attorney(s) appearing for the Case

E. Steeves Smith, for the petitioners.

Mary E. Pierce, for the respondent.

OPINION

COHEN, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes for 1981, 1982, and 1983 in the amounts of $12,886.58, $14,351.28, and $15,703.37, respectively. After concessions, the issues for determination are (1) whether payments received by petitioners under the Water Bank Program, 16 U.S.C. sec. 1301 et seq., are excludable from income under section 126(a)(3)

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