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BOGLE v. COMMISSIONER

Docket No. 1665-80.

46 T.C.M. 1487 (1983)

T.C. Memo. 1983-587

Dorothy T. Bogle v. Commissioner.

United States Tax Court.

Filed September 22, 1983.

Attorney(s) appearing for the Case

Joel S. Marcus, 10850 Wilshire Blvd., Los Angeles, Calif., for the petitioner. Dennis Brager and Michael R. Morris, for the respondent.

Memorandum Opinion

SIMPSON, Judge:

This matter is before us on the Commissioner's motion for summary judgment. A hearing was held on the motion, at which the petitioner did not appear.

The Commissioner determined a deficiency of $298,650.94 in the petitioner's Federal income tax for 1976. The sole issue for decision is whether the petitioner, who made a gift of stock on condition that the donees pay the...

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