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RACMP ENTERPRISES, INC. v. COMMISSIONER

Docket No. 23954-97.

114 T.C. 211 (2000)

RACMP ENTERPRISES, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 30, 2000.

Attorney(s) appearing for the Case

Kevin P. Courtney, for petitioner.

Steven Walker, for respondent.

PARR, Judge:*

Respondent determined an $82,577 income tax deficiency for petitioner's tax year ended August 31, 1994, and a section 66621 accuracy-related penalty of $16,515.

The issues for determination are: (1) Whether the material provided by petitioner in accordance with its contract to construct and place concrete foundations, driveways, and walkways...

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