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JRJ EXPRESS INCORPORATED v. COMMISSIONER

Docket No. 21439-96.

75 T.C.M. 2397 (1998)

T.C. Memo. 1998-200

JRJ Express Incorporated, A California Corporation, d/b/a King Express International v. Commissioner.

United States Tax Court.

Filed June 2, 1998.

Attorney(s) appearing for the Case

William E. Crockett, Encino, Calif., for the petitioner. Marilyn Devin, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

JACOBS, Judge:

Respondent determined a $1,008,874 deficiency in petitioner's Federal income tax for tax year ended April 30, 1993, and a $201,775 section 6662(a) accuracy-related penalty.

All section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Following a concession by respondent, we must decide...

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