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PERRY FUNERAL HOME, INC. v. COMMISSIONER

Docket No. 14722-02.

86 T.C.M. 713 (2003)

T.C. Memo. 2003-340

Perry Funeral Home, Inc. v. Commissioner.

United States Tax Court.

Filed December 16, 2003.

Attorney(s) appearing for the Case

Edward DeFranceschi, David Klemm, and Jason Bell, for the petitioner.

Louise R. Forbes, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

WHERRY, Judge:

Respondent determined the following deficiencies and penalty with respect to petitioner's Federal income taxes for the calendar years 1996 and 1997:

   Year   Deficiency   Penalty I.R.C. Sec. 6662

   1996   $1,044,037                $106,877.80
   1997        1,817                          -

After concessions by the parties, the principal issues for decision are:

...

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