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WRIGHT v. COMMISSIONER

Dkt. No. 9988-03.

89 T.C.M. 662 (2005)

T.C. Memo. 2005-5

Thomas G. Wright and Estate of Rosemary K. Wright, Deceased, Thomas G. Wright, Personal Representative v. Commissioner.

United States Tax Court.

January 13, 2005.

Attorney(s) appearing for the Case

James R. Cooper, for petitioners.

Richard J. Hassebrock, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

WHERRY, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes for their 1999 and 2000 taxable years in the amounts of $3,347 and $4,570, respectively. The issues for decision are:

(1) Whether, pursuant to section 1051, 104(a)(3), or 72 petitioners may exclude from gross income a portion of payments received by Thomas G. Wright (Mr. Wright) from the State...

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