Roger M. Dolese and Susan B. Dolese v. Commissioner of Internal Revenue

JOHN P. MOORE, Circuit Judge.

Roger M. Dolese and Susan B. Dolese appeal, from a decision of the United States Tax Court, Dolese v. Commissioner of Internal Revenue, 82 T.C. 830 (1984), affirming the Commissioner’s determination of deficiencies in appellants’ 1976 and 1977 income taxes. 1 Pursuant to 26 U.S.C. § 482, 2 the Commissioner of Internal Revenue reallocated interests in two tracts of land distributed by a partnership to its only partners, Roger Dolese and his wholly-owned corporation, to reflect each partner’s interest in the partnership. The original distribution, which was…