COMBS II v. COMMISSIONER

Docket No. 39233-85.

57 T.C.M. 288 (1989)

T.C. Memo. 1989-206

Leslie Combs II v. Commissioner.

United States Tax Court.

Filed May 1, 1989.


Attorney(s) appearing for the Case

Charles R. Hembree, 500 Kincaid Towers, Lexington, Ky., for the petitioner. Frederick W. Krieg, for the respondent.


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 13711 et seq....

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