FRAZIER v. COMMISSIONER

Docket No. 9145-72.

34 T.C.M. 951 (1975)

T.C. Memo. 1975-220

Frederick M. Frazier and Alicia Frazier v. Commissioner.

United States Tax Court.

Filed July 3, 1975.


Attorney(s) appearing for the Case

Paul R. Hodgson, Harvard Tower, Tulsa, Okla., and James R. Hays, for the petitioners. Randolph A. Monsur, for the respondent.


Memorandum Findings of Fact and Opinion

GOFFE, Judge:

The Commissioner determined a deficiency in petitioners' Federal income tax for the taxable year 1969 in the amount of $278,919.24. The issues for decision are:

(1) Whether the Commissioner abused his discretion under section 482 of the Code1 in allocating to Petitioner Frederick M. Frazier gain from the sale of his interest in appreciated real property distributed...

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