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LONG v. COMMISSIONER

Docket No. 36064-87.

93 T.C. 5 (1989)

WILLIAM R. LONG, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 11, 1989.

Attorney(s) appearing for the Case

Frank P. Meadows, Jr., for the petitioner.

James E. Gray, for the respondent.

OPINION

WHITAKER, Judge:

By statutory notice dated August 14, 1987, respondent determined a deficiency in petitioner's 1981 Federal income tax in the amount of $139,981.41. The issues before us are whether the terms of a closing agreement with respect to certain section 4821 adjustments between corporations controlled by petitioner have been complied with, and if not, the consequences...

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