Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined a deficiency of $12,270.00 in petitioner's 1976 Federal income tax. After concessions, the issue is whether petitioner assigned an interest in a certain claim for damages, and if so, whether such assignment effectively shifted the burden of taxation on a portion of the damages subsequently recovered.
Findings of Fact
Some of the facts are stipulated and found accordingly...
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