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BONNER v. COMMISSIONER

Docket No. 3763-77.

39 T.C.M. 403 (1979)

T.C. Memo. 1979-435

Fred G. Bonner and Marie M. Bonner v. Commissioner.

United States Tax Court.

Filed October 24, 1979.

Attorney(s) appearing for the Case

Thomas D. Roberts, for the petitioners. David Roth, for the respondent.

Memorandum Findings of Fact and Opinion

FAY, Judge:

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

  Year                      Deficiency

  1973 .................... $18,793.00
  1974 ....................  60,926.00

Because of concessions, the issues remaining for our decision involve only 1974 and are (1) whether petitioner Fred G. Bonner's receipt of $250,000 from his wholly owned subchapter...

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