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HANSEN v. COMMISSIONER

Docket No. 240-69.

33 T.C.M. 43 (1974)

T.C. Memo. 1974-12

Priscilla Hansen v. Commissioner.

United States Tax Court.

Filed January 22, 1974.

Attorney(s) appearing for the Case

Joel Kamens, 120 Milk, Boston, Mass., for the petitioner. Edward DeFranceschi, for the respondent.

Memorandum Opinion

TIETJENS, Judge:

The Commissioner determined a deficiency of $33,211.33 in petitioner's income tax for 1965. This case was fully stipulated pursuant to Rule 122, Tax Court Rules of Practice and Procedure. The facts which we deem necessary for decision will be referred to below.

The sole question for decision1 is whether $150,000 received by petitioner in settlement of a suit for compensation for services...

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