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ROCKWELL INN, LTD. v. COMMISSIONER

Docket No. 21842-91.

65 T.C.M. 2374 (1993)

T.C. Memo. 1993-158

Rockwell Inn, Ltd., Victor L. Anderes, Tax Matters Person v. Commissioner.

United States Tax Court.

Filed April 13, 1993.

Attorney(s) appearing for the Case

John S. Elias, 331 Fulton St., Peoria, Ill., for the petitioner. John Q. Walsh, for the respondent.

Memorandum Findings of Fact and Opinion

RUWE, Judge.

In notices of final S corporation administrative adjustment (FSAA's) dated August 8, 1991, respondent determined that Rockwell Inn, Ltd. (Rockwell), had not made a valid election to be treated as an S corporation.1 Respondent determined adjustments to Rockwell's S corporation returns for the taxable years 1983 and 1984, accordingly. The issues for decision are: (1) Whether...

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