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ESTATE OF LAY v. COMMISSIONER OF INTERNAL REVENUE

No. 15732-09.

T.C. Memo. 2011-208

ESTATE OF KENNETH L. LAY, DECEASED, LINDA P. LAY, INDEPENDENT EXECUTRIX AND LINDA P. LAY, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed August 29, 2011.

Attorney(s) appearing for the Case

Charles H. Egerton and Jane Dunlap Callahan , for petitioners.

Stephen R. Takeuchi , for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GOEKE, Judge.

This case involves a deficiency of $3,910,000 determined by respondent in the 2001 Federal income tax of Kenneth L. Lay and Linda P. Lay (the Lays). The deficiency is based upon respondent's determination that the Lays received income as a result of the sale of two annuity contracts to Enron Corp. (Enron). For the reasons stated herein, we find that they did not receive the income determined by respondent...

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