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KAY v. COMMISSIONER

Docket No. 5547-69.

30 T.C.M. 745 (1971)

T.C. Memo. 1971-173

Andrew F. Kay and Mary M. Kay v. Commissioner.

United States Tax Court.

Filed July 22, 1971.

Attorney(s) appearing for the Case

Clyde R. Maxwell, for the petitioners. Allan D. Teplinsky, for the respondent.

Memorandum Findings of Fact and Opinion

RAUM, Judge:

The Commissioner determined the following deficiencies in petitioners' income tax for the calendar years 1965 and 1966:

  Year                      Deficiency

  1965 ...................   $84,103
  1966 ...................     7,132

Two issues remain for adjudication: (1) What was the fair market value of 100,000 shares of Delta Design, Inc., on May 8, 1965, when petitioner...

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