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NEW YORK FOOTBALL GIANTS, INC. v. COMMR.

Docket No. 8563-00.

117 T.C. 152 (2001)

117 T.C. No. 15

NEW YORK FOOTBALL GIANTS, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 30, 2001.

Attorney(s) appearing for the Case

Michael A. Guariglia, for petitioner.

Julia A. Cannarozzi, for respondent.

OPINION

COLVIN, Judge:

Respondent determined that petitioner is liable for built-in gains tax of $574,000 for fiscal year 1996,1 $914,334 for fiscal year 1997, and $220,156 for fiscal year 1998, and for accuracy-related penalties under section 6662(a) of $114,800 for fiscal year 1996, $182,867 for fiscal year 1997, and $44,031 for fiscal year 1998. Petitioner has been an S corporation...

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