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McGowan v. Commissioner

Docket No. 13587-01.

87 T.C.M. 1421 (2004)

T.C. Memo. 2004-146

Paul McGowan v. Commissioner.

United States Tax Court.

June 21, 2004.

Attorney(s) appearing for the Case

Daniel L. Britt, Jr., for petitioner.

Travis T. Vance III, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

FOLEY, Judge:

The issues for decision are whether petitioner is liable for deficiencies and fraud penalties relating to 1991, 1992, and 1993.

FINDINGS OF FACT

In 1968, petitioner began operating McGowan Construction Company, Inc. (the Company), an S corporation. Petitioner is the president and sole shareholder of the Company.

In 1987, petitioner...

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