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ABC RENTALS OF SAN ANTONIO, INC. v. COMMISSIONER

Docket Nos. 20689-91, 20690-91, 20691-91.

77 T.C.M. 1229 (1999)

T.C. Memo. 1999-14

ABC Rentals of San Antonio, Inc., et al. v. Commissioner.

United States Tax Court.

Filed January 25, 1999.

Attorney(s) appearing for the Case

Timothy P. O'Sullivan, Wichita, Kan., and John R. Gerdes, for the petitioners. Michael J. O'Brien, for the respondent.

SUPPLEMENTAL MEMORANDUM FINDINGS OF FACT AND OPINION

HAMBLEN, Judge:

This case is before us on remand from the Court of Appeals for the Tenth Circuit. ABC Rentals of San Antonio, Inc. v. Commissioner [98-1 USTC ¶ 50,340], 142 F.3d 1200 (10th Cir. 1998), revg. and remanding [Dec. 50,278(M)] T.C. Memo. 1994-601.

The issues for decision concern the proper election and...

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