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BAYLEY v. COMMISSIONER

Docket No. 8992-73.

69 T.C. 234 (1977)

ALAN J. BAYLEY AND BARBARA F. BAYLEY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 15, 1977.

Attorney(s) appearing for the Case

Lawrence A. Aufmuth and Arthur C. Rinsky, for the petitioners.

Eugene H. Ciranni, for the respondent.

FORRESTER, Judge:

Respondent has determined a deficiency in petitioners' Federal income tax for the taxable year 1968 in the amount of $16,922.95. There are two issues for our decision: (1) Whether the stock issued to petitioner Alan J. Bayley in 1966 as compensation for promotional services was subject to restrictions which had a significant effect on its value; and, if so, (2) whether such restrictions were removed, or ceased to have a significant effect...

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