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FRANCISCO v. COMMISSIONER

Docket No. 7670-00.

119 T.C. 317 (2002)

119 T.C. No. 20

JOHN A. FRANCISCO, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 19, 2002.

Attorney(s) appearing for the Case

Daniel R. King and Richard T. Luoma, for petitioner.

Peter C. Rock, for respondent.

COLVIN, Judge:

Respondent determined deficiencies of $18,324, $52,870, and $31,913 and section 6662(a)1 accuracy-related penalties2 of $3,665, $10,574, and $6,383 relating to petitioner's 1995, 1996, and 1997 Federal income taxes, respectively.

The issues for decision are:

(1) Whether the section 931(a) exclusion applies even though the Secretary has not issued regulations under section...

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