Branum

MANSELL W. BRANUM, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Branum

Docket No. 18178-90

United States Tax Court

T.C. Memo 1993-8; 1993 Tax Ct. Memo LEXIS 9; 65 T.C.M. (CCH) 1715;

January 11, 1993, Filed

Decision will be entered for respondent.

For Petitioners: William P. Bowers and Carolyn M. Beckett.

For Respondent: Martin M. Van Brauman.

RAUM

RAUM

MEMORANDUM OPINION

RAUM, Judge: The Commissioner determined a deficiency in petitioner's Federal income tax in the amount of $ 1,006,569 for the tax year 1982.

A number of issues have been settled, and the only matter now in dispute is whether…