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VAINISI v. COMMISSIONER OF INTERNAL REVENUE

Nos. 23699-06, 23701-06

132 T.C. No. 1

JEROME R. VAINISI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent. DORIS L. VAINISI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed January 15, 2009.

Attorney(s) appearing for the Case

Frank J. O'Connell, Jr., for petitioners.

Lawrence C. Letkewicz and Christa A. Gruber, for respondent.

OPINION

FOLEY, Judge:

After concessions, the sole remaining issue for decision is whether section 291(a)(3)1 applies to a qualified subchapter S subsidiary bank. The parties submitted this case fully stipulated pursuant to Rule 122.

Background

Petitioners Jerome Vainisi and Doris Vainisi own 70.29 percent and 29.71 percent, respectively, of First Forest Park Corp. (First Forest), which was incorporated as a...

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