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McINTOSH v. COMMISSIONER

Docket No. 21618-81.

85 T.C. 31 (1985)

JOHN McINTOSH, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 16, 1985.

Attorney(s) appearing for the Case

Lane M. Hauge and Lynn M. Seelye, for the petitioner.

Richard Jones and J.A. Lopata, for the respondent.

OPINION

CLAPP, Judge:

Respondent determined a deficiency in petitioner's Federal income tax for the year 1978 in the amount of $129,398. After concessions, the sole issue for decision is whether the transfer of a one-half interest in appreciated ranch land by John McIntosh to his former wife pursuant to a divorce settlement agreement is a taxable event.

This case was submitted fully stipulated pursuant to Rule 122, Tax Court Rules of Practice...

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