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PRIMCO MANAGEMENT COMPANY v. COMMISSIONER

Docket No. 13146-96.

74 T.C.M. 177 (1997)

T.C. Memo. 1997-332

Primco Management Company, Alfred Dreyfus Goldman Revocable Living Trust, Alfred D. Goldman, Fiduciary, Tax Matters Person v. Commissioner.

United States Tax Court.

Filed July 23, 1997.

Attorney(s) appearing for the Case

Clarke Lewis Randall, Oklahoma City, Okla., for the petitioner. William A. Heard III, for the respondent.

MEMORANDUM OPINION

ARMEN: Special Trial Judge:

This matter is before the Court on petitioner's Motion to Dismiss for Lack of Jurisdiction. The issue to be decided is whether an S corporation, whose sole shareholders are two grantor trusts, constitutes a "small S corporation" within the meaning of section 301.6241-1T(c) (2), Temporary Proced. & Admin. Regs., 52 Fed. Reg. 3003 (Jan. 30, 1987), that is excluded from the unified S corporation audit and litigation...

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