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PATTERSON v. COMMISSIONER

Docket No. 697-72.

32 T.C.M. 181 (1973)

T.C. Memo. 1973-39

Lloyd Patterson and Charlene Patterson v. Commissioner.

United States Tax Court.

Filed February 15, 1973.

Attorney(s) appearing for the Case

Charles H. Creason, P.O. Box 335, Rupert, Idaho, for the petitioners. David R. Brennan, W. Durrell Nielsen and C. Garold Sims, for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

Respondent determined a deficiency of $5,167.14 in petitioners' Federal income tax for the year 1969.

Concessions having been made by the parties, the only issue remaining for our decision is whether the petitioners constructively received in 1969 an $18,000 payment actually received from J.R. Simplot Company on January 5, 1970.

Findings of Fact

Some of the facts have been stipulated...

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