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SAKOL v. COMMISSIONER

Docket No. 4834-74.

67 T.C. 986 (1977)

MIRIAM SAKOL, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 23, 1977.

Attorney(s) appearing for the Case

Burton G. Lipsky, for the petitioner.

Peter Matwiczyk, for the respondent.

OPINION

GOFFE, Judge:

The Commissioner determined a deficiency in petitioner's Federal income tax for the taxable year 1972 in the amount of $3,318.80. Concessions having been made, the sole issue for decision is whether section 83(a)1 is unconstitutional because it measures petitioner's gross income derived from an employee stock purchase agreement without regard to certain contractually...

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