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BURWELL v. COMMISSIONER

Docket No. 6493-82.

51 T.C.M. 6 (1985)

T.C. Memo. 1985-583

Clifton J. Burwell and Ginette A. Burwell v. Commissioner.

United States Tax Court.

Filed December 2, 1985.

Attorney(s) appearing for the Case

Phillip K. Fife, 70 Universal City Plaza, Los Angeles, Calif., for the petitioners. Irene Scott Carroll, for the respondent.

Memorandum Findings of Fact and Opinion

STERRETT, Chief Judge:

By notice of deficiency dated December 23, 1981, respondent determined a deficiency in petitioners' Federal income tax for the taxable year ended December 31, 1976 in the amount of $20,133. The issues before us are: (1) whether respondent is estopped from determining a deficiency in petitioners' 1976 tax, and, if not, (2) whether petitioners recognized gain due to the assumption of the partnership...

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