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EDWARD D. ROLLERT RESIDUARY TRUST v. COMMISSIONER

Docket No. 16418-79

80 T.C. 619 (1983)

EDWARD D. ROLLERT RESIDUARY TRUST, GENESEE MERCHANTS BANK & TRUST CO., TRUSTEE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court

Filed March 31, 1983

Attorney(s) appearing for the Case

Russell E. Bowers and Richard B. Covey, for the petitioner.

Beth L. Williams, for the respondent.

OPINION

WHITAKER, Judge:

Respondent determined deficiencies in petitioner's Federal income taxes in the amounts of $83,795 for 1973; $68,686 for 1974; and $2,675 for 1975.

This case was submitted fully stipulated under Rule 122, Tax Court Rules of Practice and Procedure. The primary issues for decision are: (1) Whether rights to receive bonus payments under the General Motors bonus plan, which were attributable to an individual's employment...

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