Memorandum Opinion
CLAPP, Judge.
By notice of final S corporation administrative adjustment (FSAA), respondent determined a $61,235 adjustment to the S corporation return of income of Ollis Brothers, Inc. (Ollis Brothers or the corporation) for the 1985 taxable year. This adjustment resulted from respondent's determination that Ollis Brothers had omitted gross receipts from its corporate tax return.
On December 10, 1990, petitioner, James D. Ollis...
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