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ESTATE OF ETOLL v. COMMISSIONER

Docket No. 7611-76.

79 T.C. 676 (1982)

ESTATE OF FRED A. ETOLL, SR., DECEASED, FRED A. ETOLL, JR., EXECUTOR, AND FREDA E. ETOLL, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 26, 1982.

Attorney(s) appearing for the Case

George A. Roland, for the petitioners.

Gerald A. Thorpe, for the respondent.

OPINION

TANNENWALD, Chief Judge:

Respondent determined a deficiency of $7,856 in petitioners' 1973 Federal income tax. The main issue for our determination is whether accounts receivable collected by Fred A. Etoll, Sr., in 1973, constitute gross income to him in that year.

This case was submitted fully stipulated. The stipulation of facts is incorporated by this reference.

The petitioners are Freda E. Etoll and the Estate of Fred A...

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