Memorandum Findings of Fact and Opinion
WELLS, Judge:
On December 13, 1990, respondent sent a notice of final S corporation administrative adjustment (FSAA) for taxable years 1983, 1984, and 1985 to Joseph Capogrosso, as tax matters person (TMP) of C&M Amusements, Inc. (C&M Amusements). C&M Amusements was a subchapter S corporation subject to subchapter S level corporation audit and litigation procedures of sections 6221-6223 for 1983, 1984,...
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