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COHN v. COMMISSIONER

Docket Nos. 3017-75, 3023-75.

73 T.C. 443 (1979)

MAURICE J. COHN AND MARGARET COHN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT HAROLD S. ELOVICH AND PHYLISS ELOVICH, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 5, 1979.

Attorney(s) appearing for the Case

Harold S. Elovich, for the petitioners.

Julius A. Jove and David A. Schmudde, for the respondent.

OPINION

TANNENWALD, Judge:

Respondent determined deficiencies in income tax against petitioners for the taxable year 1970 as follows:

        Docket No. 3017-75 --------    $4,705
        Docket No. 3023-75 --------     6,094

The sole issue for decision is whether section 831 applies to a situation wherein restricted stock is received by a person not an...

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