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TWENTY-THREE NINETEEN CREEKSIDE, INC. v. COMMISSIONER

Docket No. 4787-90.

65 T.C.M. 2469 (1993)

T.C. Memo. 1993-179

Twenty-Three Nineteen Creekside, Inc., Alvis Minick Rushton, Tax Matters Person, Petitioner v. Commissioner.

United States Tax Court.

Filed April 22, 1993.

Attorney(s) appearing for the Case

Alvis M. Rushton, pro se. Shellyanne W.L. Chang, for respondent.

Memorandum Opinion

FAY, Judge:

A number of issues have been settled by the parties, and the only issue now in dispute is whether Twenty-Three Nineteen Creekside, Inc. (hereinafter 2319 Creekside), is subject to the unified audit and litigation procedures under the provisions of subchapter D, chapter 63, subtitle F, of the Internal Revenue Code of 1954 (tax treatment of Subchapter S items). Once this Court resolves this underlying issue, the parties have...

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