LEARNER v. COMMISSIONER

Docket No. 4355-80.

45 T.C.M. 922 (1983)

T.C. Memo. 1983-122

Paul W. Learner and Kathryn Learner v. Commissioner.

United States Tax Court.

Filed March 9, 1983.


Attorney(s) appearing for the Case

Jay R. Oliff, 1625 The Alameda, San Jose, Calif., for the petitioners. Elizabeth I. Abreu, for the respondent.


Memorandum Findings of Fact and Opinion

SHIELDS, Judge:*

Respondent determined a deficiency of $184,863 in petitioners' 1976 Federal income tax. Due to concessions by both parties, the issues remaining for our decision are: (1) the fair market value of an office building and real property located in Eureka, California as of March 19, 1976; (2) the fair market value of shares in a closely-held corporation as of December 1976;...

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