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GULFSTREAM LAND & DEVELOPMENT CORP. v. COMMISSIONER

Docket No. 479-77.

71 T.C. 587 (1979)

GULFSTREAM LAND AND DEVELOPMENT CORPORATION AND SUBSIDIARIES, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 22, 1979.

Attorney(s) appearing for the Case

Jules I. Whitman and Thomas E. Doran, for the petitioners.

Alan Summers, for the respondent.

OPINION

GOFFE, Judge:

The Commissioner determined deficiencies in the Federal income tax of petitioners for the taxable years ended September 30, 1973, and September 30, 1974, in the respective amounts of $272,354 and $2,183,413. We have this matter before us on petitioners' motion for partial summary judgment.1

Two issues are presented:

(1) Whether any material facts are in issue so as to preclude a decision...

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