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BENSON v. COMMISSIONER

Docket Nos. 6543-78, 7979-79, 9601-80.

80 T.C. 789 (1983)

MARION B. BENSON, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 26, 1983.

Attorney(s) appearing for the Case

Jed Gladstein, for the petitioner.

David L. Denier, for the respondent.

FORRESTER, Judge:

Respondent has determined deficiencies of $4,280.20, $3,863, and $2,452 in petitioner's Federal income taxes for the years 1974, 1975, and 1976, respectively, and an addition to tax pursuant to section 6653(a)1 of $214.01 for 1974. Respondent having conceded the section 6653(a) addition to tax, the following issues remain for our decision:

(1a) Whether a transaction between petitioner and a trust established...

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