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SENNETT v. COMMISSIONER

Docket No. 6169-72.

80 T.C. 825 (1983)

WILLIAM SENNETT AND SANDRA SENNETT, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 2, 1983.

Attorney(s) appearing for the Case

Harry Margolis, for the petitioners.

M. Catherine McKenna, for the respondent.

OPINION

GOFFE, Judge:

The Commissioner determined a deficiency in petitioners' Federal income tax for the taxable year 1969 in the amount of $65,351 together with an addition to tax for the same year under section 6653(a) in the amount of $3,268. Respondent has conceded the addition to tax and one of the adjustments contained in the statutory notice of deficiency.

The issue for decision is whether section 704(d) allows a former partner to...

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