BREWER QUALITY HOMES, INC. v. COMMISSIONER

Docket No. 8222-99.

86 T.C.M. 29 (2003)

T.C. Memo. 2003-200

Brewer Quality Homes, Inc. v. Commissioner.

United States Tax Court.

Filed July 10, 2003.


Attorney(s) appearing for the Case

R. Cody Mayo, Jr., for the petitioner.

Mary Beth Calkins and Joseph Ineich, for the respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

CHABOT, Judge:

Respondent determined deficiencies in Federal corporate income tax against petitioner as follows:

Year                           Deficiency

1995 .......................   $123,602
1996 .......................    144,411

After concessions by respondent,1 the issue for decision is the extent to which amounts that

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