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WOLFSON v. COMMISSIONER

Docket No. 9132-78.

45 T.C.M. 244 (1982)

T.C. Memo. 1982-698

Jack Wolfson v. Commissioner.

United States Tax Court.

Filed November 29, 1982.

Attorney(s) appearing for the Case

Samuel R. Miller, for the petitioner. Thomas G. Potts, for the respondent.

Memorandum Findings of Fact and Opinion

CHABOT, Judge:

Respondent determined a deficiency in Federal individual income tax against petitioner for 1976 in the amount of $408. After a concession by petitioner as to one of the two adjustments in the notice of deficiency, the issues for decision are:

(1) Whether there was a debt (within the meaning of sec. 166)1 to petitioner from a woman on account of petitioner's transfer...

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