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DEAN v. COMMISSIONER

Docket No. 2216-68.

56 T.C. 895 (1971)

GEORGE A. DEAN AND MARGARET S. DEAN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed July 29, 1971.

Attorney(s) appearing for the Case

George L. Gisler, for the petitioners.

Wayne A. Smith, for the respondent.

FORRESTER, Judge:

Respondent has determined deficiencies in petitioners' income tax of $4,612.19 and $5,657.45 for the taxable years ending in 1962 and 1963, respectively. The principal issue we must decide is whether certain payments received by petitioners during the years in issue constituted consideration for the transfer of property. Whether we may reach a consideration of this issue on its merits depends upon...

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