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HANSEN v. COMMISSIONER OF INTERNAL REVENUE

No. 16247-07.

T.C. Memo. 2009-87

JUSTIN W. HANSEN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed April 28, 2009.

Attorney(s) appearing for the Case

Michael B. Kratville, for petitioner.

J. Anthony Hoefer, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

CHIECHI, Judge.

Respondent determined a deficiency of $25,998 in, and an accuracy-related penalty of $5,200 under section 6662(a)1 on, petitioner's Federal income tax (tax) for his taxable year 2004.

The issue remaining for decision is whether petitioner is entitled for his taxable year 2004 to exclude from gross income under section 104(a)(2) $100,000 of the total of $120,000 that...

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