ADVANCED DELIVERY AND CHEMICAL SYSTEMS NEVADA, INC. v. COMMISSIONER

MEMORANDUM FINDINGS OF FACT AND OPINION

SWIFT, Judge:

Respondent determined deficiencies in petitioner's Federal income taxes for petitioner's short taxable year beginning October 8 and ending December 31, 1996, and for petitioner's short taxable year beginning January 1 and ending October 10, 1997, as follows:

Short Taxable Year Ending           Deficiency

Dec. 31, 1996 ...................  $  494,101
Oct. 10, 1997 ..........

                    
                    
                    

                        

                            

                                

                            
                            

                                

                                    

                                        

                                        

                                        

                                    
                                
                                

                                    
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