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WRIGHT v. COMMISSIONER

Docket No. 3134-77.

40 T.C.M. 781 (1980)

T.C. Memo. 1980-279

Douglas A. and Mary Wright v. Commissioner.

United States Tax Court.

Filed July 29, 1980.

Attorney(s) appearing for the Case

Brian A. Steenson, Garthe Brown and Lee A. Hansen, 705 Standard Plaza, Portland, Ore., counsel for petitioners. Jan R. Pierce, counsel for respondent.

Memorandum Findings of Fact and Opinion

NIMS, Judge:1

The respondent determined a deficiency in income tax due from the petitioners for the taxable year 1972 in the amount of $124,131. The issues remaining for decision are as follows:

1. The amount realized pursuant to section 10012 on the sale of certain oil and gas exploratory permits;

2. The proper manner of allocating losses between...

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