T.C. Memo. 2004-244
UNITED STATES TAX COURT
ROGER L. WATKINS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 19587-02. Filed October 26, 2004.
Eric J. Zinn and Gregory W. Berger, for petitioner.
Mary T. Klaasen, for respondent.
MEMORANDUM OPINION
HAINES, Judge: Respondent determined a $518,463 deficiency
in petitioner’s Federal income tax for 1998 (year in issue). The
sole issue for decision is whether petitioner’s receipt of
$2,614,744 in exchange for an assignment of a right to receive
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