MARCUS v. COMMISSIONER

Docket No. 8403-94.

71 T.C.M. 2823 (1996)

T.C. Memo. 1996-190

M. Bennett Marcus and Maria F. Marcus v. Commissioner.

United States Tax Court.

Filed April 22, 1996.


Attorney(s) appearing for the Case

Robert C. Forst, Los Angeles, Calif., for the petitioners. Lisa W. Kuo, for the respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

VASQUEZ, Judge:

Respondent determined a deficiency in petitioners' 1990 Federal income tax in the amount of $16,532 and a penalty under section 6662(a)1 in the amount of $3,306. After concessions,2 the issues for decision are:

(1) Whether $37,898 received by petitioners was a tax-free inheritance under section 102(a) or the proceeds from the sale of...

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