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The parties stipulated that petitioner’s interest in the
Partnership was 5 percent and that the Partnership had a gain of
$1,239,600. Therefore, 5 percent of that amount, the $61,983
reported on the Schedule K-1, is the “distributive share” which
petitioner must report as her gross income. Sec. 702(c).
Accordingly, we sustain respondent’s determination.
Decision will be entered
for respondent.
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Last modified: May 25, 2011