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SUMMIT SHEET METAL CO. v. COMMISSIONER

Docket No. 20131-93.

72 T.C.M. 1606 (1996)

T.C. Memo. 1996-563

Summit Sheet Metal Co. v. Commissioner.

United States Tax Court.

Filed December 30, 1996.

Attorney(s) appearing for the Case

Elliott H. Kajan and Steven R. Mather, Beverly Hills, Calif., for the petitioner. Lisa A. Kuo and T. Elizabeth Stetson, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge.

Respondent determined a deficiency in petitioner's Federal income tax of $307,671 for 1987.

Petitioner is an S corporation. An S corporation is liable for tax on net recognized built-in gain if that gain exceeds 50 percent of its taxable income for the year in issue. Sec. 1374(a).1 Respondent determined that petitioner...

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