WOLLMAN, Circuit Judge.
The Commissioner of Internal Revenue terminated the Subchapter S election of Forest Knolls Estates, Inc. (Corporation), a Minnesota corporation, for taxable years 1979 and 1980. Appellant-shareholders, Aaron and Dixie Stover, seek reversal of the Tax Court decision which sustained Commissioner's action. 53 T.C.M. (P-H) ¶ 84 (1984). The Tax Court ruled that Commissioner had properly terminated Corporation's Subchapter S election pursuant...
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