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ROCKSON v. COMMISSIONER

Docket No. 3769-74.

35 T.C.M. 1286 (1976)

T.C. Memo. 1976-288

George J. Rockson and Ruth U. Rockson v. Commissioner.

United States Tax Court.

Filed September 9, 1976.

Attorney(s) appearing for the Case

J.C. DeDobbeleer, for the petitioners. Peter Bakutes, for the respondent.

Memorandum Findings of Fact and Opinion

HALL, Judge:

Respondent determined a deficiency of $2,568.54 in petitioners' 1971 Federal income tax.

The issue for decision is whether a lump sum payment received by petitioner George J. Rockson from his employer was paid for the release of petitioner's rights under an employment agreement or for the release of his rights under a contingent share agreement...

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