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).
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