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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