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ATHANASIOS v. COMMISSIONER

Docket No. 20105-93.

69 T.C.M. 1902 (1995)

T.C. Memo. 1995-72

Speros and Maria Athanasios v. Commissioner.

United States Tax Court.

Filed February 15, 1995.

Attorney(s) appearing for the Case

James L. Chase, 101 E. Government St., Pensacola, Fla., for the petitioners. Linda J. Wise, for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

Respondent determined a deficiency of $168,946 in petitioners' 1989 Federal income tax. After concessions, we must decide (1) to what extent petitioners qualify for nonrecognition treatment pursuant to section 3551 on the receipt of stock distributed in the corporate split-off transaction involved in this case, and (2) the amount of gain petitioners must recognize on the...

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