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KARTRUDE v. C.I.R.

No. 89-6148 Non-Argument Calendar.

925 F.2d 1379 (1991)

Gordon R. KARTRUDE, Jr., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

March 11, 1991.

Attorney(s) appearing for the Case

Gordon R. Kartrude, Jr., Plantation, Fla., pro se.

Gary Allen, Chief, Tax Div., Appellate Div., U.S. Dept. of Justice, Janet Bradley, Michael L. Paup, David I. Pincus, Tax Div., Washington, D.C., for respondent-appellee.

Before FAY, CLARK and BIRCH, Circuit Judges.

CLARK, Circuit Judge:

Taxpayer Gordon Kartrude appeals from a decision of the Tax Court determining deficiencies in his income tax and various additions for the 1980 and 1982 tax years. For the following reasons, this decision is affirmed in part, reversed in part and remanded for a redetermination of the taxpayer's liability.

I.

In 1974, Kartrude purchased for $26,000 fifty percent of the stock of Sport Aircraft,

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