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PLUMB v. COMMISSIONER

Docket No. 25344-89.

97 T.C. 632 (1991)

RAY PLUMB, JR., AND JACQUELYN PLUMB, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 12, 1991.

Attorney(s) appearing for the Case

Bruce Locke, Lawrence Sherlock, and L. Don Knight, for the petitioners.

M. Kathryn Bellis, for the respondent.

OPINION

RAUM, Judge:

The Commissioner determined a deficiency in petitioners' income tax for their 1983 taxable year in the amount of $311,657. At the time petitioners filed the petition herein, they resided in Houston, Texas. This case was submitted on a stipulation of facts and exhibits. Petitioners attempted in their 1984 and 1985 returns to make an election under section 172(b)(3)(C) (now 172(b)(3)) of...

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