MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
Jack M. Lenavitt petitioned the Court to readjust respondent's adjustments to subchapter S corporation items reported by Trinity Meadows Raceway, Inc. (Trinity), for 1991. On April 14, 1996, respondent issued a notice of final S corporation administrative adjustment, stating, with respect to 1991, that respondent had increased Trinity's ordinary income by $233,661 and disallowed its $2,028,750 casualty...
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