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ROTH v. COMMISSIONER

Docket No. 7094-74.

36 T.C.M. 1742 (1977)

T.C. Memo. 1977-426

Melvin and Ruth Roth v. Commissioner.

United States Tax Court.

Filed December 19, 1977.

Attorney(s) appearing for the Case

John M. Sullivan and Edwin P. Lee, 2200 First National Bldg., St. Paul, Minn., for the petitioners. Rick K. Budd, for the respondent.

Memorandum Findings of Fact and Opinion

SIMPSON, Judge:

The Commissioner determined deficiencies in the petitioners' Federal income taxes of $9,469.12 for 1968 and $176,359.99 for 1969. The parties have settled some of the issues; the sole issue remaining for decision is the fair market value of 652,074 shares of unregistered common stock on December 26, 1969.

Findings of Fact

Some of the facts have been stipulated, and those facts are...

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