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RUDD v. COMMISSIONER

Docket No. 21794-93.

70 T.C.M. 223 (1995)

T.C. Memo. 1995-350

John A. and Geraldine C. Rudd v. Commissioner.

United States Tax Court.

Filed July 31, 1995.

Attorney(s) appearing for the Case

John A. and Geraldine C. Rudd, pro se. Shuford A. Tucker, Jr. and Charles Pillitteri, for the respondent.

MEMORANDUM OPINION

COHEN, Judge:

Respondent determined deficiencies of $10,937.72 and $2,303.00 in petitioners' Federal income taxes for 1990 and 1991, respectively. The sole issue for decision is whether petitioners timely filed an Election by a Small Business Corporation (Form 2553), electing S corporation status for Blackberry Patch of Tallahassee, Inc. (Blackberry Patch), for the years in issue. Unless otherwise indicated, all section references are...

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