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UPHAM v. COMMISSIONER

Docket No. 23053-85.

57 T.C.M. 508 (1989)

T.C. Memo. 1989-253

John D. Upham and Estate of Marion B. Upham, Deceased, John D. Upham, Personal Representative v. Commissioner.

United States Tax Court.

Filed May 24, 1989.

Attorney(s) appearing for the Case

Jerome R. Rosenberg and Robert A. Sternbach, for the petitioners. Carolyn S. Rose and Craig Connell, for the respondent.

Memorandum Findings of Fact and Opinion

JACOBS, Judge:

Respondent determined a deficiency in petitioners' 1981 Federal income taxes in the amount of $2,776. At trial, respondent moved that the Court determine that the entire 1981 deficiency was attributable to a tax motivated transaction under section 6621(c) of the Internal Revenue Code of 1986.1 The deficiency arises as a result of the disallowance of petitioner John D. Upham...

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