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MATTHIES v. COMMISSIONER

Docket No. 22196-07.

134 T.C. 141 (2010)

KARL L. MATTHIES AND DEBORAH MATTHIES, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed February 22, 2010.

Attorney(s) appearing for the Case

Richard A. Sirus, for petitioners.

Naseem J. Khan and David S. Weiner, for respondent.

THORNTON, Judge:

For each of petitioners' taxable years 2000 and 2001, respondent determined a $294,925 deficiency and a $58,985 accuracy-related penalty for negligence under section 6662(a).1 After concessions, the issues for decision are: (1) Whether in 2000 petitioners realized $1,053,304 of taxable income from a bargain sale to Karl L. Matthies (petitioner) of a life insurance policy...

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