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GARVEY v. COMMISSIONER

Docket No. 13712-81.

51 T.C.M. 1026 (1986)

T.C. Memo. 1986-200

Olive W. Garvey v. Commissioner.

United States Tax Court.

Filed May 19, 1986.

Attorney(s) appearing for the Case

Edmund R. Learned, and Robert A. Page, for the petitioner. Charles N. Woodward, for the respondent.

Memorandum Opinion

CLAPP, Judge:

Respondent determined a deficiency of $748,147.09 in petitioner's 1977 income tax and an addition to tax under section 6653(a)1 in the amount of $37,407.35. After concessions, including a concession by respondent that petitioner is not liable for the negligence addition under section 6653(a), the issue for decision is whether petitioner must include in taxable income for the year 1977 the ordinary...

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