GARRETT v. COMMISSIONER

Docket No. 9034-92.

66 T.C.M. 905 (1993)

T.C. Memo. 1993-453.

Garrett & Garrett, P.C. v. Commissioner.

United States Tax Court.

Filed September 28, 1993.


Attorney(s) appearing for the Case

William Allan Garrett and Joseph M. Garrett (officers), 700 Main St., Danville, Va., for the petitioner. John C. McDougal, for the respondent.


Memorandum Findings of Fact and Opinion

KÖRNER, Judge:

By notice of deficiency dated March 9, 1992, respondent determined with regard to petitioner's 1988 corporate income tax a deficiency in the amount of $11,886.

After concessions,1 the sole issue for decision is whether petitioner has made a valid election to be an S corporation under section 1362 for the year...

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