United States Tax Court August 8, 2007, 10434-05 (Michael v. Domulewicz and Mary Ann Domulewicz v. Commissioner)

129 T.C. No. 3

UNITED STATES TAX COURT

MICHAEL V. DOMULEWICZ AND MARY ANN DOMULEWICZ, Petitioners v.

COMMISSIONER OF INTERNAL REVENUE, Respondent

Docket No. 10434-05. Filed August 8, 2007.

As part of a Son-of-BOSS transaction designed to

create a basis of approximately $29.3 million in

publicly traded stock purchased at a relatively minimal

cost, P entered into a short sale of U.S.