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BURNSIDE v. COMMISSIONER

Docket No. 10828-92.

67 T.C.M. 2557 (1994)

T.C. Memo. 1994-138

Donna Burnside and Estate of Vernile L. Burnside, Deceased, Donna Burnside, Personal Representative v. Commissioner.

United States Tax Court.

Filed March 30, 1994.

Attorney(s) appearing for the Case

M. Gary Atkinson, for the petitioners. Victor A. Ramirez, for the respondent.

Memorandum Opinion

DAWSON, Judge:

Respondent determined a deficiency of $11,454 in petitioners' 1988 Federal income tax and additions to tax pursuant to sections 6653(a)(1)1 and 6661(a) in the respective amounts of $168 and $2,864.

The issues for decision are: (1) Whether petitioners may exclude, under section 105, distributions that Vernile L. Burnside received from the Union Pacific Railroad Co. (Union Pacific) during...

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