Lori M. & John M. Mingo v. Commissioner

T.C. Memo. 2013-149

UNITED STATES TAX COURT LORI M. MINGO AND JOHN M. MINGO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 17753-07, 21906-10. Filed June 12, 2013. Harold A. Chamberlain, for petitioners. Andrew Michael Tiktin, for respondent. MEMORANDUM OPINION PARIS, Judge: In these consolidated cases, respondent issued two notices of deficiency, taking alternative positions with respect to the reporting of petitioners’ sale of a partnership interest in tax year 2002. On May 23, 2007, respondent issued a notice of deficiency to petitioners for tax year 2003 -2- [*2]…