- 2 - section 104(a)(2).1 We find that respondent’s determination was in error regarding $1,257,500 of the amount in dispute. FINDINGS OF FACT Petitioners were married and filed a joint Federal income tax return for 1992. Respondent issued a notice of deficiency to petitioners on October 10, 1996. Petitioners timely petitioned this Court. At the time they filed the petition, petitioners resided in Los Angeles, California. Mr. Wright died on January 1, 1999, at the age of 78. Mrs. Wright had died on January 1, 1998. Their daughter was appointed as the administratrix of her parents’ estates by the Superior Court of California for the County of Los Angeles. In the mid-1960s, Mr. Wright organized Marvin Engineering Co., Inc. (MEC), a California corporation, with Marvin Gussman and Gerald Friedman. MEC’s primary business was making parts for the aerospace and defense industries. Mr. Gussman served as the president and chief executive officer, and Mr. Friedman served as the chief financial officer. Mr. Wright was an engineer for MEC and worked in production and the development of new products. Mr. Wright was also a director of MEC. 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 NextLast modified: November 10, 2007