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SIMONS v. COMMISSIONER

Docket No. 12098-82.

53 T.C.M. 959 (1987)

T.C. Memo. 1987-270

John B. Simons and Della D. Simons v. Commissioner.

United States Tax Court.

Filed June 2, 1987.

Attorney(s) appearing for the Case

George R. Kucera, for the petitioners. Alan S. Beinhorn, for the respondent.

Memorandum Findings of Fact and Opinion

CLAPP, Judge:

Respondent determined a $79,425.00 deficiency in petitioners' 1978 Federal income tax. After concessions, the issue for decision is the amount of petitioners' distributive share of partnership income taxable to them.

Findings of Fact

Some of the facts have been stipulated and are found accordingly. The stipulation of facts and the exhibits...

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