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MILLER v. U.S.

CIV. A. No. 4:88-cv-192-HLM.

710 F.Supp. 1377 (1989)

Charles D. MILLER, a Notice Shareholder Other Than Tax Matters Person, in Multitex Corporation of America, Petitioner, v. UNITED STATES of America, Defendant.

United States District Court, N.D. Georgia, Rome Division.

April 10, 1989.

Attorney(s) appearing for the Case

David DeCoursey Aughtry, Chamberlain Hrdlicka White, Johnson & Williams, Atlanta, Ga., for Charles D. Miller, a Notice Shareholder, other than tax matters person, in Multitex Corporation of America.

Sharon Douglas Stokes, Office of U.S. Atty., Atlanta, Ga., Curtis L. Bowman, U.S. Dept. of Justice, Tax Div., Washington, D.C., for United States.

ORDER

HAROLD L. MURPHY, District Judge.

Charles D. Miller is a shareholder of Multitex Corporation of America (Multitex). Multitex is an "S corporation" and, for the years 1983, 1984 and 1985, Multitex reported its operations for income tax purposes by passing its tax consequences through to its three shareholders and paying taxes at the shareholder level.

In 1988, the Tax Commissioner mailed a Notice of Final S Corporation Administrative Adjustment...

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