ZAPPO v. COMMISSIONER

Docket No. 6436-78.

81 T.C. 77 (1983)

ANGELO ZAPPO AND DOROTHY ZAPPO, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 3, 1983.


Attorney(s) appearing for the Case

Donald J. Holzman, for the petitioners.

Louis J. Zeller, Jr., for the respondent.


SHIELDS, Judge:

Respondent determined a deficiency of $18,040.20 and an addition to tax under section 6653(b)1 of $9,020.10 in petitioners' Federal income taxes for 1974. Due to concessions by the parties, the sole remaining issue is whether petitioners had taxable gain in 1974 resulting from a settlement agreement made between petitioner Angelo Zappo (Zappo) and certain of his creditors.

FINDINGS OF FACT

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