Brian L. and Carole J. Nahey v. Commissioner

111 T.C. No. 13

UNITED STATES TAX COURT BRIAN L. AND CAROLE J. NAHEY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8497-96. Filed October 21, 1998. W, a corporation, sued X for breach of contract and misrepresentation for failing to complete the installation of a computer system and sought damages for lost profits. X counterclaimed for withheld payments by W. In 1986, P, through his two S corporations, acquired all of the assets and assumed all of the liabilities of W, including W's lawsuit against X and X's counterclaim against W. W was thereafter liquidated. No part…