MEMORANDUM OPINION
RUWE, Judge:
Respondent determined a deficiency of $43,564 in petitioners' 1992 Federal income tax. The sole issue for decision is whether respondent may employ the doctrine of substantial compliance in order to treat petitioners' S corporation as having made a valid election under section 1368(e)(3)(A).
Background
The parties submitted this case fully stipulated pursuant to Rule 122...
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