SUDER v. COMMISSIONER OF INTERNAL REVENUE

Docket Nos. 14435-09, 14460-09, 6183-10, 6210-10.

T.C. Memo. 2014-201

ERIC G. SUDER, ET AL., Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed October 1, 2014.


Attorney(s) appearing for the Case

Jeremy M. Fingeret , John H. Dies , and Robert G. Wonish II , for petitioners.

Julie Ann P. Gasper , Lauren Laravia , and Duy P. Tran , for respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

VASQUEZ, Judge.

In 1987 petitioner Eric Suder found himself unemployed when his employer, Candela Electronics (Candela), went out of business. As he searched for a new job, an opportunity presented itself. He recalled that Candela had sold a large volume of its private branch exchanges (PBXs) to Radio Shack, and that Radio Shack had little success in reselling them. He contacted Radio Shack and succeeded in negotiating...

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