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WOLMAN v. COMMISSIONER

Docket No. 18953-02.

88 T.C.M. 462 (2004)

T.C. Memo. 2004-262

Roger Leslie Wolman and Caroline R. Wolman v. Commissioner.

United States Tax Court.

November 16, 2004.

Attorney(s) appearing for the Case

Roger Leslie Wolman and Caroline R. Wolman, pro sese;

Sara J. Barkley, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

HAINES, Judge:

Respondent determined deficiencies of $1,600 and $88,434 in petitioner Roger Wolman's (Mr. Wolman's) and petitioner Caroline Wolman's (Mrs. Wolman's), collectively petitioners', Federal income taxes for 1998 and 1999, respectively (years in issue). The sole issue for decision is whether petitioners' receipt of $20,000 and $550,000, in 1998 and 1999, respectively, in exchange for an assignment of a right...

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