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McMANUS v. COMMISSIONER

Docket No. 5356-77.

41 T.C.M. 1322 (1981)

T.C. Memo. 1981-196

Thomas K. McManus and Margaret F. McManus v. Commissioner.

United States Tax Court.

Filed April 22, 1981.

Attorney(s) appearing for the Case

Paul E. Anderson, 235 Montgomery St., San Francisco, Calif., for the petitioners. Jerome Borison and Rebecca T. Hill, for the respondent.

Memorandum Findings of Fact and Opinion

TIETJENS, Judge:*

Respondent determined a deficiency of $106,118 in petitioners' Federal income tax for 1973. The only issue is whether petitioners are entitled to capital gains treatment for the sales of two parcels of Tract 2347.

Findings of Fact

Some of the facts have been stipulated and are so found. The stipulation...

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