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WING v. COMMISSIONER

Docket No. 11994-81.

81 T.C. 17 (1983)

SAMUEL E. WING, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 11, 1983.

Attorney(s) appearing for the Case

Theodore Z. Gelt, Lewis H. Mathis, and Joseph B. Hurst, Jr., for the petitioner.

Glenn D. Wilkinson, William F. Garrow, and James F. Podheiser, for the respondent.

OPINION

DAWSON, Chief Judge:

Respondent determined a deficiency in petitioner's Federal income tax in the amount of $25,888 for the taxable year ended December 31, 1977.

The issues presented for decision are: (1) Whether the amendment to section 1.612-3(b)(3), Income Tax Regs., by the T.D. 7523 is valid; and (2) if so, whether any portion of the $60,000 amount paid1 by petitioner in the form of cash plus a nonrecourse...

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