Docket No. 22392-91.

72 T.C.M. 816 (1996)

T.C. Memo. 1996-447

Jonathan B. Geftman v. Commissioner.

United States Tax Court.

Filed September 30, 1996.

Attorney(s) appearing for the Case

Steven M. Kwartin, Martin J. Nash, Michael B. Axman, and William J. Palmer, for the petitioner. Stephen R. Doroghazi and Kenneth A. Hochman, for the respondent.


LARO, Judge:

Jonathan B. Geftman petitioned the Court to redetermine respondent's determination of a $13,043 deficiency in his 1985 Federal income tax, a $3,261 addition thereto under section 6651(a), and a $754 addition thereto under section 6654(a).1

We must decide:

1. Whether amounts paid to petitioner, as sole beneficiary of a trust, are includable in his 1985 gross...

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