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PUGH v. COMMISSIONER

Docket No. 27237-96.

77 T.C.M. 1367 (1999)

T.C. Memo. 1999-38

James H. Pugh, Jr., and Alexis C. Pugh v. Commissioner.

United States Tax Court.

Filed February 8, 1999.

Attorney(s) appearing for the Case

Charles H. Egerton, Orlando, Fla., and Jane D. Callahan, for the petitioners. Judith C. Winkler, for the respondent.

MEMORANDUM OPINION

COHEN, Chief Judge:

Respondent determined deficiencies in petitioners' Federal income tax of $83,181 and $76,723 and penalties under section 6662(c) of $16,636 and $15,432 for the taxable years 1990 and 1991, respectively. After concessions, the issues for decision are:

(1) Whether petitioner James H. Pugh, Jr. (petitioner), may increase his basis in stock of an S corporation by the amount of discharge of indebtedness income (also...

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