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SCHAEFER v. COMMISSIONER

Docket No. 6555-94.

105 T.C. 227 (1995)

WILLIAM H. SCHAEFER, JR., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 13, 1995.

Attorney(s) appearing for the Case

Allen L. Schwait, for petitioner.

Helen F. Rogers, for respondent.

OPINION

RAUM, Judge:

The Commissioner determined deficiencies in petitioner's income taxes totaling $8,688, $55,383, and $11,461 for the years 1988, 1989, and 1990, respectively. Following concessions by petitioner, the sole issue before us is whether income received pursuant to a covenant not to compete is passive income for purposes of section 469.1 More specifically at issue is the validity of section 1.469-2T(c)(7...

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