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PAGEL, INC. v. COMMISSIONER

Docket No. 34122-85.

91 T.C. 200 (1988)

PAGEL, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 8, 1988.

Attorney(s) appearing for the Case

John W. Lundquist, for the petitioner.

Gail K. Gibson and James K. Harris, for the respondent.

WELLS, Judge:

Respondent determined a deficiency in petitioner's Federal income tax for the year ending March 31, 1982, in the amount of $195,782.54. After concessions, the remaining issue is whether petitioner realized capital gain or ordinary income upon the sale by petitioner to its sole shareholder of a warrant to purchase stock in another corporation.

PRELIMINARY MATTER

When the instant case was...

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