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MORTON v. COMMISSIONER

Docket No. 26651-93.

73 T.C.M. 2520 (1997)

T.C. Memo. 1997-166

Nathan P. and Geraldine V. Morton v. Commissioner.

United States Tax Court.

Filed April 1, 1997.

Attorney(s) appearing for the Case

James L. Kissire, Dallas, Tex., and Bob J. Shelton, for the petitioners. John Repsis, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

WHALEN, Judge:

Respondent determined the following deficiency in, and penalty on, petitioners' Federal income tax for 1989:

Deficiency   Sec. 6662 Penalty

$296,702          $59,340

Unless stated otherwise, all section references are to the Internal Revenue Code as in effect for 1989. After concessions, the issues remaining for decision are: (1) Whether the fair market value...

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