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PERACCHI v. COMMISSIONER

Docket No. 22511-93.

71 T.C.M. 2830 (1996)

T.C. Memo. 1996-191

Donald J. and Judith E. Peracchi v. Commissioner.

United States Tax Court.

Filed April 22, 1996.

Attorney(s) appearing for the Case

Craig A. Houghton, Fresno, Calif., for the petitioners. Mary P. Kimmel, for the respondent.

MEMORANDUM OPINION

NIMS, Judge:

Respondent determined a $172,967 deficiency in petitioners' 1989 Federal income tax. The deficiency results from respondent's determination that petitioners realized a $566,806 gain on the transfer of certain properties to their wholly owned corporation, and the resulting arithmetically required reduction in the deductible amount of a conceded casualty loss.

Since the parties agree that the deductible amount of petitioners...

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