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RECOVERY GROUP, INC. v. COMMISSIONER OF INTERNAL REVENUE

Nos. 12430-08, 29314-07, 29321-07, 29326-07, 29333-07, 29335-07, 29336-07, 29385-07

T.C. Memo. 2010-76

RECOVERY GROUP, INC., ET AL., Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed April 15, 2010.

Attorney(s) appearing for the Case

Peter L. Banis and D. Sean McMahon, for petitioners.

Paul V. Colleran, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GUSTAFSON, Judge.

These cases are before the Court pursuant to section 6213(a)2 for redetermination of deficiencies in tax and penalties for 2002 and 2003, which the Internal Revenue Service (IRS) determined against Recovery Group, Inc. (Recovery Group), and its shareholders. The determination against Recovery Group, an S corporation, was made pursuant to section 1374 (see infra note 5...

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