BANAITIS v. COMMISSIONER

SIGITAS J. BANAITIS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

BANAITIS v. COMMISSIONER

No. 4323-00

United States Tax Court

T.C. Memo 2002-5; 2002 Tax Ct. Memo LEXIS 4; 83 T.C.M. (CCH) 1053;

January 8, 2002, Filed

Judgment entered for respondent.

Joseph Wetzel and Michael C. Wetzel, for petitioner.

Shirley M. Francis, for respondent.

Gerber, Joel

GERBER

MEMORANDUM FINDINGS OF FACT AND OPINION

GERBER, Judge: Respondent determined a $ 1,708,216 deficiency in income tax for petitioner's 1995 taxable year. The issues for our consideration are: (1) Whether petitioner is entitled to exclude…