Memorandum Findings of Fact and Opinion
BEGHE, Judge:
By notice of final S corporation administrative adjustment (FSAA), respondent determined a $2,179,217 adjustment to the S corporation return of income of Praxiteles, Inc., for the taxable year 1985. This adjustment resulted from the disallowance of deductions for interest, maintenance and insurance, option fees, professional fees, and a filing fee.
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