Charles A. Buda and Annette H. Buda - Page 1

                                 T.C. Memo. 1999-132                                  

                               UNITED STATES TAX COURT                                

                 CHARLES A. BUDA AND ANNETTE H. BUDA, Petitioners v.                  
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 16309-96.             Filed April 21, 1999.                 

               Robert S. Marquis, for petitioners.                                    
               Kirk S. Chaberski, for respondent.                                     

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               FOLEY, Judge:  By notice dated July 17, 1996, respondent               
          determined a $1,181,285 deficiency in petitioners' 1988 Federal             
          income tax.  The issues for decision are as follows:                        
               1.  What was the nature and value of the leasehold interest            
          that Mr. Buda received on liquidation of his wholly owned S                 
          corporation?  We hold that Mr. Buda received the right to use,              

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