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HALBERT v. COMMISSIONER

Docket No. 7065-76.

37 T.C.M. 408 (1978)

T.C. Memo. 1978-88

Gary C. Halbert and Nancy L. Halbert v. Commissioner.

United States Tax Court.

Filed March 2, 1978.

Attorney(s) appearing for the Case

Joel M. Butler, 9744 Wilshire Blvd., Beverly Hills, Cal., for the petitioners. M.K. Mortensen and W. Winter Nesbitt, III, for the respondent.

Memorandum Findings of Facts and Opinion

RAUM, Judge:

The Commissioner determined the following deficiencies in petitioners' joint Federal income taxes:

  Year                   Deficiency

  1971 ...............   $14,173.76
  1972 ...............    11,136.54
  1973 ...............     9,860.00

The only issue raised by the Commissioner's determination is whether any portion of the $750,000 which petitioners received in connection...

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