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TAPROOT ADMINISTRATIVE SERVICES, INC. v. COMMISSIONER OF INTERNAL REVENUE

No. 15396-07.

133 T.C. No. 9

TAPROOT ADMINISTRATIVE SERVICES, INC., Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed September 29, 2009.

Attorney(s) appearing for the Case

Steven R. Mather and Kenneth M. Barish, for petitioner.

David W. Sorensen, for respondent.

OPINION

WHERRY, Judge.

This case, which involves a petition for redetermination of a deficiency for petitioner's 2003 tax year, is before the Court on respondent's October 23, 2008, motion for partial summary judgment. See Rule 121(a).1 Respondent argues that petitioner is not eligible for S corporation status during 2003 because it had an ineligible shareholder—a Roth individual retirement account (Roth IRA)—during...

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