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JUDEN v. COMMISSIONER

Docket No. 40595-84.

53 T.C.M. 1154 (1987)

T.C. Memo. 1987-302

Charles A. Juden and Cleo M. Juden v. Commissioner.

United States Tax Court.

Filed June 22, 1987.

Attorney(s) appearing for the Case

John L. Oliver, Jr., 400 Broadway, Cape Girardeau, Mo., for the petitioners. James A. Kutten, for the respondent.

Memorandum Findings of Fact and Opinion

GERBER, Judge:

In a statutory notice of deficiency, dated September 13, 1984, respondent determined a $121,389 income tax deficiency for petitioners' 1979 taxable year. The entire deficiency is attributable to respondent's proposed disallowance of a substantial amount of basis claimed in connection with a purported sale of realty during 1979. The controversy over the deficiency has generated the following issues

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