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PHILLIPS v. COMMISSIONER

Docket No. 7996-96.

74 T.C.M. 187 (1997)

T.C. Memo. 1997-336

Julius R. Phillips and Marcia G. Phillips v. Commissioner.

United States Tax Court.

Filed July 24, 1997.

Attorney(s) appearing for the Case

Michael Hinchion, Nashville, Tenn., for the petitioners. Edsel Ford Holman, Jr., for the respondent.

MEMORANDUM OPINION

PARR, Judge:

This case is before us on the parties' cross-motions for summary judgment under Rule 121.1 Respondent determined a deficiency in petitioners' Federal income tax in the amount of $30,920 for the taxable year 1992. The term "petitioner" refers to Julius R. Phillips.

The issue for decision is whether petitioner may exclude from gross income under section 104(a)(2) amounts received from his...

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