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VECCHIO v. COMMISSIONER

Docket No. 11928-91.

103 T.C. 170 (1994)

SAM J. VECCHIO, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 15, 1994.

Attorney(s) appearing for the Case

Robert J. Vecchio, for petitioner.

Dawn Marie Krause, for respondent.

PARKER, Judge:

Respondent determined a deficiency in petitioner's Federal income tax for the taxable year 1980 in the amount of $286,693. In an amendment to answer, respondent later asserted an increased deficiency of $349,198.25.

After concessions,1 the primary issue to be decided is the amount of gain resulting from the sale of real property by Johanna Properties Partnership that properly is allocable to petitioner and...

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