Spector v. Commissioner

BERNARD D. SPECTOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Spector v. Commissioner

Docket No. 2498-77.

United States Tax Court

T.C. Memo 1982-433; 1982 Tax Ct. Memo LEXIS 318; 44 T.C.M. (CCH) 631; T.C.M. (RIA) 82433;

July 28, 1982.

Bernard D. Spector, pro se.

James R. Turton, for the respondent.

TANNENWALD

SUPPLEMENTAL MEMORANDUM FINDINGS OF FACT AND OPINION

TANNENWALD, Chief Judge: This case is again before us on remand from the Fifith Circuit Court of Appeals. In our original opinion, Spector v. Commissioner,71 T.C. 1017 (1979), we held that, although a transaction was in form a…