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HANG v. COMMISSIONER

Docket No. 9367-89.

95 T.C. 74 (1990)

WILLIAM M. HANG AND DEBORAH S. HANG AND DAVIDAN ORTHODONTIC LAB, INC., DAVID R. HANG, TAX MATTERS PERSON, DEBORAH S. HANG, GUARDIAN AND DANIEL W. HANG, A PERSON OTHER THAN THE TAX MATTERS PERSON, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 18, 1990.

Attorney(s) appearing for the Case

Charles T. Shea and Dennis R. Pearson, for the petitioners.

Mary P. Hamilton and Ronald F. Hood, for the respondent.

OPINION

HAMBLEN, Judge:

This case is before us on petitioners' motion to dismiss and/or for partial judgment on the pleadings. Respondent issued notices of Final S Corporation Administrative Adjustment (FSAA) for the S corporation returns of Davidan Orthodontic Lab, Inc. (Davidan), for the taxable years 1984 and 1985. Respondent made no adjustment to ordinary income for Davidan for either 1984 or 1985. However, respondent determined that for Federal...

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