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PAULSEN v. COMMISSIONER

Docket No. 17549-79.

78 T.C. 291 (1982)

HAROLD T. AND MARIE B. PAULSEN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 2, 1982.

Attorney(s) appearing for the Case

Duane Tewell and David Tewell, for the petitioners.

Wayne R. Appleman, for the respondent.

OPINION

FEATHERSTON, Judge:

Respondent determined a deficiency in the amount of $40,913 in petitioners' Federal income tax for 1976. The only issue for decision is whether the exchange of "guaranty stock" in a State-chartered savings and loan association for passbook accounts and time certificates of deposit in a federally chartered mutual savings and loan association qualifies as a tax-free exchange under...

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