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BLANCO INVESTMENTS & LAND, LTD. v. COMMR.

Docket No. 14022-87.

89 T.C. 1169 (1987)

BLANCO INVESTMENTS & LAND, LTD., JACK M. LITTLE, TAX MATTERS PERSON, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 10, 1987.

Attorney(s) appearing for the Case

Frank L. Swan, for the petitioner.

William Sabin and Henry Schneiderman, for the respondent.

OPINION

WILLIAMS, Judge:

This case is before us on petitioner's motions to dismiss for lack of jurisdiction and for litigation costs. The Commissioner determined adjustments to Blanco Investments & Land, Ltd.'s (Blanco) S corporation return for its 1983 taxable year as set forth in a Notice of Final S Corporation Administrative Adjustment.

Petitioner contends that Blanco was exempt from the S corporation audit and litigation procedures...

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