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ESTATE OF NEWMAN v. COMMISSIONER

Docket No. 4224-49.

59 T.C.M. 543 (1990)

T.C. Memo. 1990-230

Estate of Michael Newman, Deceased, Sidney Newman, Executor, and Alice Newman, Executor, and Alice Newman v. Commissioner.

United States Tax Court.

Filed May 10, 1990.

Attorney(s) appearing for the Case

Steven Kamerman, 500 Fifth Ave., New York, N.Y., for the petitioners. Curt M. Rubin, for the respondent.

Memorandum Opinion

WELLS, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for taxable year 1977 in the amount of $109,230. The issues for us to decide concern petitioners' proper distributive share of ordinary income and capital gain from the partnership known as Digitax of Michigan (hereinafter "Digitax"). For convenience we will combine our findings of fact and opinion.

The facts are fully stipulated. The stipulation...

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