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HOME OF FAITH v. C.I.R.

No. 93-9020.

39 F.3d 263 (1994)

HOME OF FAITH, doing business as Ambassador Manor South; Jerry L. Franks, A Person Other Than the Tax Matters Person, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Tenth Circuit.

November 1, 1994.

Attorney(s) appearing for the Case

Herbert P. Haschke, Jr., Tulsa, OK, for petitioners/appellant.

Andrea R. Tebbets, Attorney, Tax Div., Dept. of Justice (Loretta C. Argrett, Asst. Atty. Gen., and Richard Farber, Attorney, Tax Div., Dept. of Justice, with her on the brief), Washington, DC, for respondent/appellee.

Before SEYMOUR, Chief Judge, McKAY, Circuit Judge, and BELOT, District Judge.

SEYMOUR, Chief Judge.

Home of Faith, an S corporation, and one of its shareholders appeal a Tax Court determination that the court had jurisdiction to redetermine adjustments made by the IRS to Home of Faith's corporate returns using entity-level audit and litigation procedures. Shareholders in S corporations generally are required to follow the entity-level audit and litigation procedures which partners in partnerships must follow when challenging IRS adjustments...

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