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IOWA SCHOOL OF MEN'S HAIRSTYLING, INC. v. COMMISSIONER

Docket No. 3993-92.

64 T.C.M. 1114 (1992)

T.C. Memo. 1992-619.

Iowa School of Men's Hairstyling, Inc. v. Commissioner.

United States Tax Court.

Filed October 21, 1992.

Attorney(s) appearing for the Case

James R. Monroe, 2115 Forest, Des Moines, Iowa, for the petitioner. Jeffrey A. Schlei, for the respondent.

Memorandum Opinion

FAY, Judge:

This case is before us on respondent's Motion for Ruling that Petitioner's Statement Pursuant to I.R.C. § 534(c) is Insufficient to Shift the Burden of Proof to Respondent. The sole issue presented is whether petitioner's statement, submitted pursuant to section 534(c),1 is sufficient to place the burden of proof on respondent with regard to the reasonableness of accumulated earnings and profits...

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