Memorandum Findings of Fact and Opinion
WRIGHT, Judge.
By a statutory notice of deficiency dated July 24, 1985, respondent determined a deficiency in petitioner's Federal income tax in the amount of $406,923.36 for taxable year 1977.
After concessions, the sole issue for our consideration is whether Spendthrift Farm, Inc., qualifies as a subchapter S corporation in taxable year 1977, pursuant to section 1371
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