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KAMPEL v. COMMISSIONER

Docket No. 5198-77.

72 T.C. 827 (1979)

DANIEL S. KAMPEL AND CLARISSE KAMPEL, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 9, 1979.

Attorney(s) appearing for the Case

Eugene L. Vogel, for the petitioners.

Joan R. Domike, for the respondent.

OPINION

FEATHERSTON, Judge:

Respondent determined a deficiency in the amount of $39,773 in petitioners' Federal income tax for 1973. The issue for decision is whether earned income, for the purposes of the 50-percent maximum tax prescribed by section 1348,1 is a sum equal to 30 percent of the total income which petitioner Daniel S. Kampel received from a partnership in which he was a member or a sum equal to both the amount...

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