STACOM v. COMMISSIONER

Docket No. 28610-88.

61 T.C.M. 2691 (1991)

T.C. Memo. 1991-231

Matthew J. Stacom and Estate of Claire P. Stacom, Deceased, Mark A. Berlin, Executor v. Commissioner.

United States Tax Court.

Filed May 23, 1991.


Attorney(s) appearing for the Case

Bernard S. Mark, Richard S. Kestenbaum and Mark A. Berlin, 599 Lexington Ave., New York, N.Y., for the petitioners. Michael D. Wilder, Roland Barral, Mark L. Hulse and Paulette Segal, for the respondent.


Memorandum Findings of Fact and Opinion

COLVIN, Judge:

Petitioners took deductions with respect to purchases and leasebacks of computer equipment. The deductions were disallowed on grounds that they were structured as a tax-avoidance scheme devoid of economic substance which should be disregarded for Federal income tax purposes.

Respondent determined deficiencies in petitioners' Federal income tax for 1978, 1979, 1980, and 1981 in the amounts of...

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