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DEYOE v. COMMISSIONER

Docket No. 2084-73.

66 T.C. 904 (1976)

ELIZABETH L. DEYOE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 30, 1976.

Attorney(s) appearing for the Case

Gary Damon, for the petitioner.

Peter Bakutes, for the respondent.

HALL, Judge:

Respondent determined the following deficiencies in petitioner's Federal income tax:

Year                         Deficiency

1969 ----------------------  $21,222.25
1970 ----------------------   26,118.93

Because of concessions made by the parties, the sole issue before the Court is whether section 1239 of the Internal Revenue Code of 19541 applies to petitioner's sale of her...

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