MEMORANDUM ON CROSS-MOTIONS FOR SUMMARY JUDGMENT
RICHARD S. STAIR, Jr., Chief Judge.
The Debtor, Trans-Lines West, Inc., a corporation, operated a business known as AAMCO Transmissions located at 8844 Kingston Pike, Knoxville, Tennessee. The Debtor owns the real estate upon which its business was operated. On April 29, 1989, the Debtor, through Internal Revenue Service Form 2553, elected to be treated as a Subchapter S corporation under the Internal...
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