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OGDEN v. COMMISSIONER

Docket No. 22866-82.

84 T.C. 871 (1985)

MARY K.S. OGDEN, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 16, 1985.

Attorney(s) appearing for the Case

D. Irvin Couvillion, for the petitioner.

A. Albert Ajubita, for the respondent.

OPINION

SIMPSON, Judge:

The Commissioner determined a deficiency of $26,814.54 in the petitioner's Federal income tax for 1978. The issues for decision are: (1) Whether a special allocation to the petitioner under a partnership agreement had substantial economic effect within the meaning of section 704(b)(2) of the Internal Revenue Code of 19541; and (2) if such special allocation lacked substantial economic effect, what...

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