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ON SHORE QUALITY CONTROL SPECIALIST, INC. v. COMMISSIONER

Docket No. 7496-94.

71 T.C.M. 2283 (1996)

T.C. Memo. 1996-95

On Shore Quality Control Specialist, Inc. v. Commissioner.

United States Tax Court.

Filed March 4, 1996.

Attorney(s) appearing for the Case

Harry E. Caylor III (an officer), for the petitioner. Joni D. Larson, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

POWELL, Special Trial Judge:

This case was assigned pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1

Respondent determined deficiencies in petitioner's Federal income taxes for the fiscal years ending August 31, 1991 and August 31, 1992, in the amounts of $2,717 and $3,120, respectively.

The sole issue is whether section 274(a)(1)(B) disallows...

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