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HAYMOND v. COMMISSIONER

Docket No. 13024-95.

73 T.C.M. 3179 (1997)

T.C. Memo. 1997-289

J. Brent Haymond and Janis S. Haymond v. Commissioner.

United States Tax Court.

Filed June 26, 1997.

Attorney(s) appearing for the Case

Earl D. Tanner, Jr., Salt Lake City, Utah, for the petitioners. David W. Sorensen, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

TANNENWALD, Judge:

Respondent determined a deficiency in petitioners' Federal income tax in the amount of $92,790.92 and a penalty under section 66621 in the amount of $18,558.00 for the taxable year 1990. The issues for decision are as follows:

(1) Whether petitioners are entitled to include an unpaid commission in the basis of stock sold by petitioner J. Brent Haymond's wholly...

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