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FRATANTONIO v. COMMISSIONER

Docket No. 45722-85.

55 T.C.M. 611 (1988)

T.C. Memo. 1988-158

Frank A. and Mary L. Fratantonio v. Commissioner.

United States Tax Court.

Filed April 18, 1988.

Attorney(s) appearing for the Case

Larry Kars, for the petitioners. Ronald F. Hood, for the respondent.

Memorandum Findings of Fact and Opinion

CLAPP, Judge:

Respondent determined a deficiency in petitioners' Federal income taxes for the taxable year 1981 of $8,336. The deficiency resulted from respondent's determination that Kent Video Tape and Disc, Ltd. ("Kent"), a corporation in which petitioners were shareholders, was not an electing small business corporation as defined in section 1371(b)1 of the Internal Revenue Code. The...

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