- 21 -
the disposition of his interest in South Texas Drilling as a sale
in order to disguise the $38,334.50 of ordinary income
received.10
To reflect the foregoing,
Decision will be entered
for respondent.
10 Based on our finding that petitioner fraudulently
underreported his income for 1978, respondent is not barred by
the section 6501(a) limitations period from assessing a
deficiency against petitioner for the taxable year in issue.
Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Last modified: May 25, 2011