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PERRYMAN v. COMMISSIONER

Docket No. 2676-86.

55 T.C.M. 1588 (1988)

T.C. Memo. 1988-378

Lawrence R. Perryman and Alice Perryman v. Commissioner.

United States Tax Court.

Filed August 16, 1988.

Attorney(s) appearing for the Case

John Gigounas, 7770 College Town Dr., Sacramento, Calif., for the petitioners. Katherine K. Vetter and Theodore Garelis, for the respondent.

Memorandum Findings of Fact and Opinion

FAY, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for the 1981 taxable year in the amount of $894,2671. The issue for decision is whether, with respect to certain oil and gas drilling rigs transferred by petitioner to his wholly owned corporation, respondent properly allocated to petitioner the pre-sale income and expenses related to such rigs, and the gain...

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