Memorandum Findings of Fact and Opinion
IRWIN, Judge:
Respondent determined a deficiency of $4,550.51 in petitioner's tax for the year ended March 31, 1976. The issue presented for decision is whether petitioner has shown good cause for the untimely filing of a shareholder agreement wherein each shareholder agreed to be jointly and severally liable in the event that the actions of petitioner, a Subchapter S corporation, required recapture of investment tax...
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