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FARMERS GIN, INC. v. COMMISSIONER

Docket No. 10142-93.

69 T.C.M. 1696 (1995)

T.C. Memo. 1995-25

Farmers Gin, Inc., F. Ronald Rayner, Tax Matters Person v. Commissioner.

United States Tax Court.

Filed January 19, 1995.

Attorney(s) appearing for the Case

Wayne A. Smith, 3300 N. Central Ave., Phoenix, Ariz., for the petitioner. Anne Durning, for the respondent.

Memorandum Findings of Fact and Opinion

WRIGHT, Judge.

Respondent determined deficiencies in Farmers Gin, Inc.'s (the corporation) 1987 and 1989 Federal income tax in the amounts of $234,373 and $15,850, respectively.

The sole issue for our consideration is whether section 1378(c)1 requires the termination of the corporation's status as an S corporation as a result of the transfer of more than 50 percent of petitioner...

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