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ETELA CUCKER, INC. v. COMMISSIONER

Docket No. 18316-89.

61 T.C.M. 1949 (1991)

T.C. Memo. 1991-68

Etela Cucker, Inc. v. Commissioner.

United States Tax Court.

Filed February 25, 1991.

Attorney(s) appearing for the Case

Donald Jay Pols, 360 Lexington Ave., New York, N.Y., for the petitioner. Lewis J. Abrahams and Janet F. Appel, for the respondent.

Memorandum Opinion

HALPERN, Judge:

By statutory notice dated May 2, 1989, respondent determined a deficiency in petitioner's Federal income tax for the taxable year 1978 of $46,289. Respondent also determined that petitioner is liable for the increased rate of interest on a substantial underpayment attributable to a tax motivated transaction. See sec. 6621(c)(1).1 Petitioner was a partner in a partnership that engaged in certain...

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