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FINE v. COMMISSIONER

Docket No. 3333-88.

58 T.C.M. 820 (1989)

T.C. Memo. 1989-640

Paul and Irma Fine v. Commissioner.

United States Tax Court.

Filed December 4, 1989.

Attorney(s) appearing for the Case

Leslie T. Jones, 360 E. Coronado Rd., Phoenix, Ariz., for the petitioners. Mary P. Kimmel, for the respondent.

Memorandum Findings of Fact and Opinion

KÖRNER, Judge:

Respondent determined a deficiency in petitioners' 1981 income tax of $8,587, and additions to tax of $429.35 under section 6653(a)(1)1 and 50 percent of the interest due on $8,587, pursuant to section 6653(a)(2). The issues presented are: (i) whether petitioners are collaterally estopped from denying that sales of land were made in the ordinary course of business and...

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