COTTLE v. COMMISSIONER

Docket No. 3524-82.

89 T.C. 467 (1987)

DONALD R. COTTLE AND JULIA A. COTTLE (NOW JULIA A. RAYL), PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 9, 1987.


Attorney(s) appearing for the Case

Curtis W. Berner, for the petitioners.

Theodore Garelis, for the respondent.


CHABOT, Judge:

Respondent determined a deficiency in Federal individual income tax against petitioners for 1977 in the amount of $177,238. After concessions by petitioners, the issues for decision are as follows:

(1) Whether petitioners properly reported the gain realized from the sale of 3 four-plex apartment buildings as long-term capital gain; and

(2) Whether a 25-percent distributive share of the income of a partnership is taxable to petitioner...

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