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BUDA v. COMMISSIONER

Docket No. 16309-96.

77 T.C.M. 1877 (1999)

T.C. Memo. 1999-132

Charles A. Buda and Annette H. Buda v. Commissioner.

United States Tax Court.

Filed April 21, 1999.

Attorney(s) appearing for the Case

Robert S. Marquis, Knoxville, Tenn., for the petitioners. Kirk S. Chaberski, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

FOLEY, Judge:

By notice dated July 17, 1996, respondent determined a $1,181,285 deficiency in petitioners' 1988 Federal income tax. The issues for decision are as follows:*

1. What was the nature and value of the leasehold interest that Mr. Buda received on liquidation of his wholly owned S corporation? We hold that Mr. Buda received the right to use, and receive all income from...

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