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Glenn Hightower, pro se.
Catherine Campbell, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge: Respondent determined deficiencies in
petitioner’s Federal individual income tax of $7,535,620 for 2000
and $389,455 for 2001. After respondent’s concession,1 the
issues for decision are:
1. Whether $41,585,388 petitioner received in 2000 in a
corporate stock buyout of his shares in an S corporation and
interest credited in 2000 and 2001 to the account in which he
deposited the payment is included in petitioner’s income for
those years. We hold that it is.
2. Whether petitioner is required to include in income for
taxable year 2000 a distributive share of the S corporation’s
2000 income. We hold that he is.
Unless otherwise indicated, section references are to the
Internal Revenue Code as amended in effect for the years in
issue, and Rule references are to the Tax Court Rules of Practice
and Procedure.
1 Respondent concedes that the amount of petitioner’s
unreported interest income for 2001 is $44,021 less than
respondent determined in the notice of deficiency.
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