CALPO HOM & DONG ARCHITECTS, INC. v. COMMISSIONER

Dkt. No. 4227-05.

93 T.C.M. 1306 (2007)

T.C. Memo. 2007-140

Calpo Hom & Dong Architects, Inc. v. Commissioner.

United States Tax Court.

June 4, 2007.


Attorney(s) appearing for the Case

Richard Todd Luoma, for petitioner.

Christian A. Speck, for respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

HAINES, Judge.

Respondent determined a deficiency of $7,506 in petitioner's 2002 Federal corporate income tax. The issue for decision is whether, during 2002, petitioner was a qualified personal service corporation as defined by section 448(d)(2).1

FINDINGS OF FACT

Some of the facts have been stipulated and are so found. The stipulation of facts, the supplemental stipulation...

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