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AmBASE CORPORATION v. COMMISSIONER

Docket No. 11816-95.

81 T.C.M. 1657 (2001)

T.C. Memo. 2001-122

AmBase Corporation, f/k/a The Home Group Inc., Individually, and AmBase Corporation, f/k/a The Home Group Inc., As Designated Agent of City Investing Company v. Commissioner.

United States Tax Court.

Filed May 23, 2001.

Attorney(s) appearing for the Case

M. Carr Ferguson, Jr., John A. Corry, Laura M. Barzilai, and Marina A. Choundas, for the petitioner.

Elsie Hall and Dante D. Lucas, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GALE, Judge:

Respondent determined deficiencies in petitioner's Federal income taxes as follows:

Year               Deficiency

1979 ............. $2,081,771
1980 .............  3,660,891
1981 .............  4,568,190
1982 .............  4,052,244
1983 .............  3,042,955
1984 .............  2,493,442
1985 .............  1,087,116

The sole issue for decision is whether...

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