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MAGNUSSEN v. COMMISSIONER

Docket No. 39661-85.

53 T.C.M. 1233 (1987)

T.C. Memo. 1987-315

Bernard L. Magnussen and Sandra C. Magnussen v. Commissioner.

United States Tax Court.

Filed June 25, 1987.

Attorney(s) appearing for the Case

John A. Runte, 1341 East Pacheco Blvd., Los Banos, Calif., for the petitioners. Debra Estrem, for the respondent.

Memorandum Findings of Fact and Opinion

PARR, Judge:

Respondent determined deficiencies in petitioners' 1980 and 1982 Federal income tax in the amounts of $71,542 and $1,975, respectively. After concessions, including a complete concession by petitioners for the 1982 deficiency, the sole issue is when, if at all, a revocation of election to have Magnussen Chevrolet Corporation ("Magnussen Chevrolet") taxed under Subchapter S of the Internal Revenue Code...

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