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GREENSPUN v. COMMISSIONER

Docket No. 4602-73.

72 T.C. 931 (1979)

HERMAN M. AND BARBARA J. GREENSPUN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 28, 1979.

Attorney(s) appearing for the Case

Edward P. Morgan and Michael H. Singer, for the petitioners.

Dennis C. DeBerry and Charles S. Triplett, for the respondent.

OPINION

FAY, Judge:

Respondent determined deficiencies in petitioners' Federal income tax as follows:

Year               Deficiency

1967 .........    $469,613.77
1969 .........   1,157,956.19

We have been asked to decide the extent to which, if any, petitioners realized income subject to taxation upon their receipt of a loan in the amount of $4 million at 3-percent interest for a period of years.

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