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RAUENHORST v. COMMISSIONER

Docket No. 1982-00.

119 T.C. 157 (2002)

119 T.C. No. 9

GERALD A. AND HENRIETTA V. RAUENHORST, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 7, 2002.

Attorney(s) appearing for the Case

John K. Steffen, Walter A. Pickhardt, and David R. Brennan, for petitioners.

David L. Zoss, for respondent.

OPINION

RUWE, Judge:

The matter is before us on petitioners' motion for partial summary judgment pursuant to Rule 121.1 Respondent determined a deficiency of $1,322,295 in petitioners' Federal income taxes, and an accuracy-related penalty of $264,459 pursuant to section 6662(a), for 1993. The issue for decision is whether the transfer of stock warrants to four charitable institutions...

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