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MOORE v. COMMISSIONER

Docket No. 32582-83.

54 T.C.M. 1407 (1987)

T.C. Memo. 1987-626

Lewis W. Moore and Shirley L. Moore v. Commissioner.

United States Tax Court.

Filed December 30, 1987.

Attorney(s) appearing for the Case

Thomas F. Topel, 401 N. 31st St., Billings, Mont., Kenneth L. Cutler, J. Marquis Eastwood, and Maureen H. Parkinson, for the petitioners. Randall G. Durfee and Joel A. Lopata, for the respondent.

Memorandum Findings of Fact and Opinion

HAMBLEN, Judge:

Respondent determined a deficiency in petitioners'1 Federal income tax for the year 1980 in the amount of $34,872.00.

The primary issues for our determination are whether the ownership interest acquired by petitioner in a sale and leaseback transaction was supported by economic substance and whether petitioner acquired...

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