MASON v. COMMISSIONER

Docket No. 23093-87.

55 T.C.M. 1134 (1988)

T.C. Memo. 1988-273

Miles H. Mason and Elizabeth D. Mason v. Commissioner.

United States Tax Court.

Filed June 27, 1988.


Attorney(s) appearing for the Case

Joseph Gardner III, 2341 Brockett Rd., Atlanta, Ga., for the petitioners. Randye D. Lloyd and Donald W. Williamson, Jr., for the respondent.


Memorandum Findings of Fact and Opinion

WILLIAMS, Judge:

The Commissioner determined a deficiency of $65,442.48 in petitioners' Federal income tax for their 1981 taxable year. The issues we must decide are (1) whether the tax consequences of petitioner Miles H. Mason's receipt of property pursuant to an agreement terminating two partnerships of which he was a member are governed by section 731

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