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111 WEST 16 ST. OWNERS, INC. v. COMMISSIONER

Docket No. 12318-87.

90 T.C. 1243 (1988)

111 WEST 16 STREET OWNERS, INC., ALAN SILVERMAN, TAX MATTERS PERSON, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court

June 23, 1988.

Attorney(s) appearing for the Case

Geoffrey J. O'Connor, for the petitioner.

Henry S. Schneiderman, for the respondent.

OPINION

WILLIAMS, Judge:

This case is before the Court on petitioner's motion to dismiss for lack of jurisdiction. The Commissioner determined adjustments to 111 West 16 Street Owners, Inc.'s (Owners) S corporation return for its 1983 taxable year as set forth in a Notice of Final S Corporation Administrative Adjustment.

Petitioner's position is that Owners was not subject to the S corporation audit and litigation procedures (secs. 6241 et...

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