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ADVANCE INTERNATIONAL, INC. v. COMMISSIONER

Docket Nos. 7749-87, 7750-87.

91 T.C. 445 (1988)

ADVANCE INTERNATIONAL, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. ADVANCE MACHINE CO., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 6, 1988.

Attorney(s) appearing for the Case

Alan W. Granwell and Michael Quigley, for the petitioners.

Beth L. Williams, for the respondent.

WHITAKER, Judge:

Respondent issued statutory notices of deficiencies to petitioners1 Advance Machine Co. (Machine) and Advance International, Inc. (International), on December 29, 1986. In the statutory notices respondent determined that International did not qualify as a domestic international sales corporation (DISC) during its fiscal years 1980, 1981, and 1982. Respondent determined the following deficiencies (which result from...

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