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PAXTON v. COMMISSIONER

Docket No. 6091-70.

57 T.C. 627 (1972)

FLOYD G. PAXTON AND GRACE D. PAXTON, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 15, 1972.

Attorney(s) appearing for the Case

Peter M. Lind and Richard Hunt, for the petitioners.

Harold E. Patterson, for the respondent.

OPINION

DAWSON, Judge:

Respondent determined a deficiency of $3,987.92 in petitioners' Federal income tax for the year 1967.

The parties have made certain concessions which can be given effect in the Rule 50 computation. The primary issue for decision is whether the F.G. Paxton Family Organization (a Trust) is a grantor trust under sections 671 through 677, I.R.C. 1954,1 the income from which in 1967 is 86.38 percent...

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