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HARRINGTON v. COMMISSIONER

Docket No. 10490-92.

67 T.C.M. 3060 (1994)

T.C. Memo. 1994-258

Joanna Harrington v. Commissioner.

United States Tax Court.

Filed June 7, 1994.

Attorney(s) appearing for the Case

John Gigounas, 50 California St., San Francisco, Calif., for the petitioner. Allan D. Hill, for the respondent.

Memorandum Opinion

RAUM, Judge:

The Commissioner determined an income tax deficiency in the amount of $64,690.50 for the taxable year ended December 31, 1984, and additions to tax for that year under sections 6653(a) and 6661 in the amounts of $3,234.55 and $16,172.75, respectively.1 The present controversy relates to the taxability of profit realized by petitioner upon a division of property between petitioner and her ex-husband...

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