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GATES v. COMMISSIONER

Docket No. 19350-05.

135 T.C. 1 (2010)

DAVID A. GATES AND CHRISTINE A. GATES, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed July 1, 2010.

Attorney(s) appearing for the Case

George J. Tomlinson, Jr., for petitioners.

Kris H. An and Jonathan H. Sloat, for respondent.

OPINION

MARVEL, Judge:

Respondent determined a deficiency in petitioners' Federal income tax of $112,553 and an addition to tax under section 6651(a)(1)1 of $11,211 for 2000. Petitioners filed a timely petition contesting respondent's determination.

After concessions,2 the issues for decision are: (1) Whether petitioners may exclude from gross...

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