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O'DONNELL v. COMMISSIONER

Docket No. 27563-82.

51 T.C.M. 266 (1986)

T.C. Memo. 1986-14

Carl M. O'Donnell and Roberta M. O'Donnell v. Commissioner.

United States Tax Court.

Filed January 13, 1986.

Attorney(s) appearing for the Case

Carl M. O'Donnell, pro se, Bedford, Mass. Christine Colley, for the respondent.

Memorandum Findings of Fact and Opinion

WHITAKER, Judge:

Respondent determined a deficiency in petitioners' 1978 Federal income tax in the amount of $2,949, together with an addition to tax of $147.45 pursuant to section 6653(a).1 The issues presented for decision are:

(1) Whether personal service income assigned by petitioners to an "Express Equity Pure Trust" is taxable to petitioners individually; (2) whether...

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