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MMC CORP. v. COMMISSIONER

Dkt. No. 14742-05.

94 T.C.M. 514 (2007)

T.C. Memo. 2007-354

MMC Corp., Midwest Mechanical Contractors, Inc., M W Builders, Inc., Midwest Mechanical Contractors of New Jersey, Inc., and Pahor Air Conditioning, Inc., Petitioners v. Commissioner.

United States Tax Court.

November 29, 2007.

Attorney(s) appearing for the Case

Michael Thompson and Lori J. Sellers, for petitioners.

Allison O. Woodbury, for respondent.

MEMORANDUM OPINION

KROUPA, Judge:

Respondent determined a $357,534 deficiency in petitioners' Federal income tax for 2000 and a $468,068 deficiency in petitioners' Federal income tax for 2001. After concessions,1 we must determine whether petitioners are required to include section 481 adjustments as recognized built-in gain for 2000 and 2001 (the years at issue).2 We hold that they are.

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