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K & R DELIVERY, INC. v. COMMISSIONER

Docket Nos. 36971-86, 37510-86.

54 T.C.M. 1376 (1987)

T.C. Memo. 1987-618

K & R Rentals, Inc. v. Commissioner.

United States Tax Court.

Filed December 23, 1987.

Attorney(s) appearing for the Case

Richard E. Brandwein, 180 N. LaSalle St., Chicago, Ill., for the petitioners. Joseph T. Ferrick, for the respondent.

Memorandum Opinion

GERBER, Judge:

This matter is before the Court on petitioners' motion under Rule 142(e),1 prior to trial, on the sufficiency of petitioners' statements under section 534(c).

On December 3, 1985, respondent, pursuant to section 534(b) notified petitioners that he would issue notices of deficiency with determinations that petitioners had accumulated earnings...

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