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WATSON v. COMMISSIONER

Docket No. 4239-76.

69 T.C. 544 (1978)

H. N. WATSON, JR., AND WIFE, SHIRLEY WATSON, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 5, 1978.

Attorney(s) appearing for the Case

J. R. Blumrosen, for the petitioners.

Charles R. Billings, for the respondent.

FEATHERSTON, Judge:

Respondent determined a deficiency in the amount of $23,319.41 in petitioners' Federal income tax for 1973. A concession on another issue having been made by petitioners, the sole issue remaining for decision is whether petitioners realized income of $42,146.51 in 1973 from the sale of 147 bales of cotton under terms pursuant to which they received an irrevocable letter of credit from a local bank in that year.

FINDINGS OF FACT...

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