THURMAN v. COMMISSIONER

Docket No. 16537-96.

75 T.C.M. 2625 (1998)

T.C. Memo. 1998-233

James L. and Leta A. Thurman v. Commissioner.

United States Tax Court.

Filed June 30, 1998.


Attorney(s) appearing for the Case

James L. Magee, Seattle, Wash., and Thomas H. Nelson, for the petitioners. Kay Hill, for the respondent.


MEMORANDUM OPINION

RUWE, Judge:

Respondent determined a deficiency of $43,564 in petitioners' 1992 Federal income tax. The sole issue for decision is whether respondent may employ the doctrine of substantial compliance in order to treat petitioners' S corporation as having made a valid election under section 1368(e)(3)(A).1

Background

The parties submitted this case fully stipulated pursuant to Rule 122...

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