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GORDON v. COMMISSIONER

Docket No. 4489-94.

73 T.C.M. 1681 (1997)

T.C. Memo. 1997-10

Marshall I. Gordon v. Commissioner.

United States Tax Court.

Filed January 7, 1997.

Attorney(s) appearing for the Case

Nathan M. Sutton, Janice S. Martin, Lyle D. Pishny, for the petitioner. Charles M. Berlau, for the respondent.

MEMORANDUM OPINION

RAUM, Judge:

The Commissioner determined a $243,216 deficiency in petitioner's 1988 Federal income tax and a $60,804 section 6661(a) addition to tax for substantial understatement. The issues are: (1) Whether petitioner (petitioner or Marshall) realized capital gain on the transfer of a 22.5-percent interest in Blackbob, a Kansas property, and (2) whether he is liable for a section 6661(a) addition to tax. The facts have been stipulated...

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