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,Page: 1 2 3 4 5 6 7 Next
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