HAYNSWORTH, Senior Circuit Judge:
The question is the interpretation of 26 U.S.C.A. § 6655(d)(2) in the context of a corporation's duty to pay in advance installments of estimated income tax liability during the first year after revocation of an election to be taxed under Subchapter S. The district court held that, since in the preceding year the corporation's net income was not subject to tax levied upon it, it could lawfully estimate its income tax for the...
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