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TREISTER v. COMMISSIONER

Docket No. 16043-79.

51 T.C.M. 418 (1986)

T.C. Memo. 1986-53

Leonard E. Treister and Diana Treister v. Commissioner.

United States Tax Court.

Filed February 6, 1986.

Attorney(s) appearing for the Case

James E. Burk and Sam Konigsberg, for the petitioners. Kevin J. Yourman and Steven Z. Ettinger, for the respondent.

Memorandum Findings of Fact and Opinion

NIMS, Judge:

Respondent determined deficiencies of $12,492 and $8,077 in petitioners' 1975 and 1976 Federal income tax returns, respectively. The sole issue for decision is whether petitioner received certain payments during 1975 and 1976 as compensation for services or in exchange for certain stock.

Findings of Fact

Some of the facts have been stipulated...

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