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HOWARD PONTIAC-GMC, INC. v. COMMISSIONER

Docket No. 4972-95.

74 T.C.M. 45 (1997)

T.C. Memo. 1997-313

Howard Pontiac-GMC, Inc., d.b.a. Bob Howard Automall v. Commissioner.

United States Tax Court.

Filed July 7, 1997.

Attorney(s) appearing for the Case

Randall K. Calvert, Oklahoma City, Okla., for the petitioner. David G. Hendricks and Michael J. O'Brien, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

VASQUEZ, Judge:

Respondent determined deficiencies in petitioner's Federal income tax of $4,689 and $24,367 for the 1990 and 1991 tax years, respectively. Petitioner purchased the inventories (parts, accessories, new and used cars) of Dave Markley Jeep-Eagle, Inc. (seller). Pursuant to a sales agreement, John David Markley (Mr. Markley), the sole shareholder and president of seller, terminated his Jeep-Eagle franchise...

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