Marshall I. Gordon, (1997)

Extract

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Marshall I. Gordon, (1997)

T.C. Memo. 1997-10

UNITED STATES TAX COURT MARSHALL I. GORDON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 4489-94. Filed January 7, 1997.

Nathan M. Sutton, Janice S. Martin, Lyle D. Pishny, for petitioner.

Charles M. Berlau, for respondent.

MEMORANDUM OPINION RAUM, Judge: The Commissioner determined a $243,216 deficiency in petitioner's 1988 Federal income tax and a $60,804 section 6661(a) addition to tax for substantial understatement. The issues are: (1) Whether petitioner (petitioner or Marshall) realized capital gain on the transfer of a 22.5-percent interest in Blackbob, a Kansas property, and (2) whether he is liable for a section 6661(a) addition to tax. The facts have bee...

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