Memorandum Findings of Fact and Opinion
JACOBS, Judge:
Respondent determined a deficiency in petitioners' 1988 Federal income tax in the amount of $109,315 and an addition to tax pursuant to section 6651(a) in the amount of $4,895.
After concessions by petitioners, the issues remaining for decision are: (1) Whether petitioners timely filed an election (on Form 2553) to have Mindies Eloy/Casa Grande, Inc., an Arizona corporation, treated as an S corporation...
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