Alain and Monique Massot - Page 1

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                                        T.C. Memo. 2000-24                                             


                                     UNITED STATES TAX COURT                                           


                           ALAIN AND MONIQUE MASSOT, Petitioners v.                                    
                        COMMISSIONER OF INTERNAL REVENUE, Respondent                                   


                  Docket No. 10086-98.                 Filed January 19, 2000.                         


                  Cynthia C. Smith and George A. Berman (specially                                     
            recognized), for petitioners.                                                              
                  Christine Colley and Maureen T. O’Brien, for respondent.                             


                           MEMORANDUM FINDINGS OF FACT AND OPINION                                     

                  JACOBS, Judge:  Respondent determined a $191,580 deficiency in                       
            petitioners’ 1992 Federal income tax.  The sole issue for decision                         
            is whether the $600,000 Alain Massot (petitioner) received in 1992