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ROTH v. COMMISSIONER

Docket No. 6872-74.

36 T.C.M. 82 (1977)

T.C. Memo. 1977-17

Earl A. Roth and Anne G. Roth v. Commissioner.

United States Tax Court.

Filed January 27, 1977.

Attorney(s) appearing for the Case

Earl A. Roth and Anne G. Roth, pro se, 75 Parting Brook Rd., New Canaan, Conn. Daniel P. Ehrenreich, for the respondent.

Memorandum Findings of Fact and Opinion

FAY, Judge:

Respondent determined a deficiency of $15,835 in petitioners' Federal income tax for 1970.

Due to a concession by petitioners, we are to decide the following:

(1) Whether petitioners are entitled to nonrecognition under either section 1033 or 10341 of any portion of the gain realized by them in 1970, through their...

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