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KINGSBURY v. COMMISSIONER

Docket No. 8444-72.

65 T.C. 1068 (1976)

HOWARD G. KINGSBURY AND ANNA Z. KINGSBURY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 3, 1976.

Attorney(s) appearing for the Case

Horace N. Freedman and Stephen Solomon, for the petitioners.

Robert G. Martinell, for the respondent.

IRWIN, Judge:

Respondent determined deficiencies in petitioners' Federal income tax as follows:

Year                       Amount

1966 --------------      $40,948.60
1967 --------------       135,905.73
1968 --------------      $25,405.00
1969 --------------       38,024.00

After concessions by the parties, the issues remaining for decision are as follows:

(1) The proper characterization...

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