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ESTATE OF HALL v. COMMISSIONER

Docket No. 26270-92.

71 T.C.M. 2276 (1996)

T.C. Memo. 1996-93

Estate of James F. Hall, Jr., Deceased, Harriett Hall, Executrix, and Harriett Nixon Hall v. Commissioner.

United States Tax Court.

Filed March 4, 1996.

Attorney(s) appearing for the Case

Neal A. Sanders and Gerard J. Serzega, Butler, Pa., for the petitioners. Julia L. Wahl, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

RUWE, Judge:

Respondent determined a deficiency of $287,624.41 in petitioners' 1988 Federal income tax.

The issues for decision are whether petitioners properly excluded from income the 1988 distribution from the Hadd-Too, Inc., Pension Plan under section 105(c)1 and, if not, whether petitioner Harriett Nixon Hall is entitled to relief from liability as an "innocent spouse" under...

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