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GRAVES v. COMMISSIONER

Docket No. 10318-85.

89 T.C. 49 (1987)

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

United States Tax Court.

Filed July 7, 1987.

Attorney(s) appearing for the Case

E. Steeves Smith, for the petitioners.

Mary E. Pierce, for the respondent.

SUPPLEMENTAL OPINION

COHEN, Judge:

On January 7, 1987, we filed our opinion at 88 T.C. 28 (1987), and directed that decision be entered under Rule 155. In that opinion we held, in part, that petitioners had not shown that the payments in question constituted the "excludable portion" of payments under the Water Bank Program, 16 U.S.C. sec. 1301 et seq., as defined in section 126(b)(1).1 Specifically...

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