SPECTOR v. COMMISSIONER

Docket No. 2498-77.

44 T.C.M. 631 (1982)

T.C. Memo. 1982-433

Bernard D. Spector v. Commissioner.

United States Tax Court.

Filed July 28, 1982.


Attorney(s) appearing for the Case

Bernard D. Spector, pro se, P.O. Box 1225, Dallas, Texas. James R. Turton, for the respondent.


Supplemental Memorandum Findings of Fact and Opinion

TANNENWALD, Chief Judge:

This case is again before us on remand from the Fifth Circuit Court of Appeals. In our original opinion, Spector v. Commissioner [Dec. 35,942], 71 T.C. 1017 (1979), we held that, although a transaction was in form a merger of two partnerships followed by a withdrawal of the petitioner from the merged partnership, there was "strong proof" to...

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