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CRANE v. COMMISSIONER OF INTERNAL REVENUE

No. 27795-09.

T.C. Memo. 2011-256

GLENN R. CRANE AND DEBORAH A. CRANE, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed November 1, 2011.

Attorney(s) appearing for the Case

Joseph Falcone , for petitioners.

Evan H. Kaploe , for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

CHIECHI, Judge.

Respondent determined a deficiency of $14,186 in, and an accuracy-related penalty of $2,284 under section 6662(a)1 on, petitioners' Federal income tax (tax) for their taxable year 2007.

The issues remaining for decision for petitioners' taxable year 2007 are:

(1) Are petitioners entitled to exclude from gross income under section 104(a)(2) an arbitration...

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