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DARDEN v. COMMISSIONER

Docket No. 20194-85.

53 T.C.M. 498 (1987)

T.C. Memo. 1987-174

Lennie F. Darden and Brenda H. Darden v. Commissioner.

United States Tax Court.

Filed March 30, 1987.

Attorney(s) appearing for the Case

Claude T. Allen, for the petitioners. Michael Urban, for the respondent.

Memorandum Findings of Fact and Opinion

POWELL, Special Trial Judge:1

The issue in this case is whether petitioners are entitled to exclude from income a portion of their 1981 income under section 911(a).2 The facts are as follows:

Since 1978 Lennie F. Darden, Jr. (petitioner)3 has been employed by the Western Company or a subsidiary (Western) as a "tool pusher...

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