MADORIN v. COMMISSIONER

Docket No. 28963-81.

84 T.C. 667 (1985)

BERNARD AND JOYCE MADORIN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 11, 1985.


Attorney(s) appearing for the Case

Stephen N. Engberg and Michael A. Klein, for the petitioners.

Judy Jacobs, for the respondent.


OPINION

DAWSON, Chief Judge:

Respondent determined a deficiency of $27,618 in petitioners' Federal income tax for the taxable year 1978. The issues for decision are: (1) Whether section 1.1001-2(c), example (5), Income Tax Regs., should be declared invalid as an unwarranted extension of sections 671, 674, and 1001;1 (2) if the regulation is valid, whether the regulation should be applied retroactively; and (3) if...

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