- 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