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RANDOLPH v. COMMISSIONER

Docket No. 10540-97.

80 T.C.M. 192 (2000)

T.C. Memo. 2000-248

Loretta Jean Randolph v. Commissioner.

United States Tax Court.

Filed August 9, 2000.

Attorney(s) appearing for the Case

Loretta Jean Randolph, pro se. J. Anthony Hoefer, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

MARVEL, Judge:

Respondent determined a deficiency in petitioner's 1994 Federal income tax of $11,148 and additions to tax under sections 6651(a)(1)1 and 6654 of $2,787 and $575, respectively. The issues for decision2 are (1) whether petitioner realized income of $50,000 under section 61(a)(12) from the discharge of

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