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THERMAL ENERGY CONCEPTS, INC. v. COMMISSIONER

Docket No. 11028-90.

66 T.C.M. 1368 (1993)

T.C. Memo. 1993-541

Thermal Energy Concepts, Inc., David Kagel, Tax Matters Person v. Commissioner.

United States Tax Court.

Filed November 22, 1993.

Attorney(s) appearing for the Case

Avram Salkin, 9100 Wilshire Blvd., Beverly Hills, Calif., for the petitioner. Sherri Munnerlyn, for the respondent.

Memorandum Opinion

FAY, Judge:

This case is before the Court on petitioner's Motion for Summary Judgment and Supplement to Petitioner's Motion for Summary Judgment pursuant to Rule 121.1 Petitioner contends that the period of limitations expired before respondent mailed the notice of final S corporation administrative adjustment (FSAA) and further that the FSAA was invalid because the provisions of the Tax Equity and Fiscal Responsibility...

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