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ABBOTTS v. COMMISSIONER

Docket No. 27154-83.

50 T.C.M. 953 (1985)

T.C. Memo. 1985-460

Thomas E. Abbotts v. Commissioner.

United States Tax Court.

Filed September 3, 1985.

Attorney(s) appearing for the Case

Vincent L. Alsfeld, for the petitioner. Christine Colley, for the respondent.

Memorandum Opinion

RAUM, Judge:

The Commissioner determined a $12,782.09 deficiency in petitioner's income tax and a $648.50 addition to tax under section 6653(a), I. R. C. 1954, for the year 1979. After concessions, the principal issue for decision is whether $3,421.44 in "[w]ages designated as sick leave" were excludable from petitioner's gross income under section 104(a)(1), I. R. C. 1954. The case was submitted fully stipulated.

Petitioner was...

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