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SMITH v. COMMISSIONER

Docket No. 4262-76.

36 T.C.M. 932 (1977)

T.C. Memo. 1977-223

John C. Smith II and Julia S. Smith v. Commissioner.

United States Tax Court.

Filed July 18, 1977.

Attorney(s) appearing for the Case

Leo C. Sherry, Jr., 2408 First Nat'l Bank Tower, Portland, Ore., for the petitioners. Jan R. Pierce, for the respondent.

Memorandum Opinion

QUEALY, Judge:

Respondent determined deficiencies in the Federal income taxes of petitioners as follows:

  Year               Deficiency

  1971 ............. $13,175.00
  1972 .............  20,116.00
  1973 .............   8,376.00

Due to concessions, the issues remaining for decision are as follows:

1. Whether payments made by petitioner for the assignment of a 20-year contract with a hospital are...

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