Modern Computer Games, Inc. v. Commissioner

MODERN COMPUTER GAMES, INC., CARL D. RADER, TAX MATTERS PERSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Modern Computer Games, Inc. v. Commissioner

Docket No. 1866-89

United States Tax Court

T.C. Memo 1989-483; 1989 Tax Ct. Memo LEXIS 483; 58 T.C.M. (CCH) 23; T.C.M. (RIA) 89483;

September 5, 1989

Gary R. DeFrang, for the petitioner.

Henry S. Schneiderman and Lisa Byun, for the respondent.

COUVILLION

MEMORANDUM OPINION

COUVILLION, Special Trial Judge: This case was assigned pursuant to the provisions of section 7443A(b) of the Internal Revenue Code of 1986. 1

This case is before the…