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COMBRINK v. COMMISSIONER

Docket No. 13580-99.

117 T.C. 82 (2001)

117 T.C. No. 8

GARY D. AND LINDY H. COMBRINK, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 15, 2001.

Attorney(s) appearing for the Case

Kerry R. Hawkins and Kenneth W. Klingenberg, for petitioners.

Brian A. Smith and C. Glenn McLoughlin, for respondent.

OPINION

NIMS, Judge:

Respondent determined a Federal income tax deficiency for petitioners' 1996 taxable year in the amount of $56,449. The principal issue to be decided is the proper application of section 304, which could in turn require application of sections 301 and 302, to the facts of this case. Additional adjustments made in the statutory notice of deficiency are computational in nature and will be resolved by our holding herein.

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