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PARKS v. COMMISSIONER

Docket No. 4417-64.

26 T.C.M. 104 (1967)

T.C. Memo. 1967-16

James R. Parks and Dorothy Parks v. Commissioner.

United States Tax Court.

Filed January 30, 1967.

Attorney(s) appearing for the Case

Eldred Dede, for the petitioners. Denis J. Conlon, for the respondent.

Memorandum Findings of Fact and Opinion

TANNENWALD, Judge:

Respondent determined a deficiency in income tax and addition to tax under section 66541 for the calendar year 1959 in the amounts of $31,032.55 and $97.79, respectively.

The only issue remaining for decision is whether petitioners constructively received ordinary income as liquidated damages from the expiration...

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