Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined deficiencies of $9,227, $5,597, and $3,360 in petitioner's Federal income taxes for 1986, 1987, and 1988, respectively. The deficiencies resulted from disallowance of claimed S corporation losses. The issue for decision is whether a timely election on Form 2553 was filed on behalf of the corporation. If we find that such an election was filed, we must decide whether the statute of...
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