DAVIES v. COMMISSIONER

Docket No. 11045-91.

101 T.C. 282 (1993)

WARNOCK DAVIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 4, 1993.


Attorney(s) appearing for the Case

James Roach II and David A. Joffe, for petitioner.

Marikay Lee-Martinez, for respondent.


OPINION

WRIGHT, Judge:

Respondent determined a deficiency in petitioner's 1987 Federal income tax in the amount of $111,155.63. The deficiency is based on a $300,700 adjustment to income. Petitioner did not contest $700 of the adjustment related to an increase in rental income. As such, only the $300,000 adjustment remains in dispute.

The sole issue for consideration for taxable year 1987 is whether under section 461(f)1...

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