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BOLLES v. COMMISSIONER

Docket No. 869-76.

69 T.C. 342 (1977)

JOHN S. BOLLES AND MARY P. BOLLES, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 30, 1977.

Attorney(s) appearing for the Case

Peter S. Buchanan and Jeffrey G. Wagner, for the petitioners.

William E. Saul, for the respondent.

FORRESTER, Judge:

Respondent has determined a deficiency in petitioners' Federal income tax for the taxable year 1969 in the amount of $107,147. There are two issues presented for our decision: (1) A determination of the fair market value of a package of securities received by petitioners on August 7, 1969; and (2) whether certain contract rights which petitioners received on August 7, 1969, had an ascertainable fair market value and, if so, a determination...

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