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WYNECOOP v. COMMISSIONER

Docket No. 3765-79.

76 T.C. 101 (1981)

THOMAS E. WYNECOOP AND SHIRLEY WYNECOOP, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 19, 1981.

Attorney(s) appearing for the Case

John Ranquet, for the petitioners.

Thomas N. Tomashek, for the respondent.

OPINION

FEATHERSTON, Judge:

Respondent determined deficiencies in the amounts of $126,912.94 and $79,609.48 in petitioners' Federal income taxes for 1975 and 1976, respectively. Due to a concession by respondent, the only issue for decision is whether certain dividends received by petitioner Thomas E. Wynecoop are exempt from Federal income taxation.

This case was submitted fully stipulated.

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