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WRIGHT v. COMMISSIONER

Docket No. 5244-88.

58 T.C.M. 369 (1989)

T.C. Memo. 1989-557

Michael Wright and Mary Ann Wright v. Commissioner.

United States Tax Court.

Filed October 11, 1989.

Attorney(s) appearing for the Case

Daniel J. Winfree, 110 West C St., San Diego, Calif., for the petitioners. Valerie K. Liu and William H. Quealy, Jr., for the respondent.

Memorandum Opinion

CLAPP, Judge:

Respondent determined a deficiency in petitioners' income tax for the taxable year 1983 in the amount of $4,904 and additions to tax under section 6653(a)(1)1 and (a)(2) in the amounts of $245 and 50 percent of interest due on the deficiency, respectively. After concessions by the parties, the sole issue remaining is whether petitioners constructively received, and should have included in their...

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