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MARSHALL v. COMMISSIONER

Docket No. 24064-87.

56 T.C.M. 1006 (1989)

T.C. Memo. 1989-5

Jimmy Rogers Marshall & Evelyn Rose Marshall v. Commissioner.

United States Tax Court.

Filed January 5, 1989.

Attorney(s) appearing for the Case

Brent Edward Vallens, for the petitioner. Mary Tseng, for the respondent.

Memorandum Findings of Fact and Opinion

NAMEROFF, Special Trial Judge:

This case was assigned pursuant to the provisions of section 7443A(b) of the Internal Revenue Code and Rules 180, 181 and 182.1 Respondent determined a deficiency in petitioners' 1985 income tax return in the amount of $5,270. The sole issue for decision is whether the amount in dispute may be excluded from gross income under section 106.

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