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WILSON v. COMMISSIONER

Docket No. 13809-89.

62 T.C.M. 900 (1991)

T.C. Memo. 1991-491

William R. and Gertrude L. Wilson v. Commissioner.

United States Tax Court.

Filed September 30, 1991.

Attorney(s) appearing for the Case

William R. Wilson, pro se. David R. Reid, for the respondent.

Memorandum Findings of Fact and Opinion

HAMBLEN, Judge:

Respondent determined a deficiency in William R. and Gertrude L. Wilson's (petitioners) Federal income tax for the taxable year 1986 in the amount of $10,900.92 and additions to tax under section 6653(a)(1)(A)1 and (B).2

The sole issue for decision is whether William R. Wilson (petitioner) is a "qualified individual" eligible to exclude...

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