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MICHAELIS NURSERY, INC. v. COMMISSIONER

Docket No. 21842-93.

69 T.C.M. 2300 (1995)

T.C. Memo. 1995-143

Michaelis Nursery, Inc., A California Corporation, Ronald J. Michaelis, Tax Matters Person v. Commissioner.

United States Tax Court.

Filed March 30, 1995.

Attorney(s) appearing for the Case

Jeffrey P. Kane and Steven M. McClean, 2445 Capital St., Fresno, Calif., for the petitioner.

William D. Reese, for the respondent.

Memorandum Findings Of Fact and Opinion

COHEN, Judge:

Respondent sent a notice of final S corporation administrative adjustment (FSAA) to Ronald J. Michaelis (petitioner) on August 9, 1993, for 1990 and 1991. The sole issue for decision is whether amounts received by Michaelis Nursery, Inc. (the corporation) from its customers in connection with the sale of trees should have been recognized as income in the year the payments were received or in subsequent...

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