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BENTLEY v. COMMISSIONER

Docket No. 9315-75.

37 T.C.M. 211 (1978)

T.C. Memo. 1978-39

Charles A. Bentley and Eva Bentley v. Commissioner.

United States Tax Court.

Filed January 30, 1978.

Attorney(s) appearing for the Case

R. Michael Wilkinson, 707 Wilshire, Los Angeles, Calif., for the petitioners. Alan R. Herson and Marion Malone, for the respondent.

Memorandum Findings of Fact and Opinion

STERRETT, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for the calendar year 1970 in the amount of $16,948.21. Petitioners concede that an additional tax is due in the amount of $1,515.21. The remainder of the deficiency determined by respondent ($15,433) is the subject of this litigation.

The sole issue before the Court is the fair market value of 20,000 shares of Portable Parking...

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