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DOTY v. COMMISSIONER

Docket No. 16089-80.

81 T.C. 652 (1983)

EDWIN DOTY AND JOYCE DOTY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 28, 1983.

Attorney(s) appearing for the Case

Jerry H. Robinson and F. Jan Blaustein, for the petitioners.

Elizabeth I. Abreu, for the respondent.

STERRETT, Judge:

By notice of deficiency dated June 12, 1980, respondent determined deficiencies in petitioners' Federal income taxes in the amounts of $107,916, $92,976, and $118,743 for the years 1975, 1976, and 1977, respectively. The sole issue for decision is whether the income received by petitioner Joyce Doty pursuant to her marriage settlement agreement constituted earned income under former section 1348, I.R.C. 1954.1<...

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