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PARKWAY GRAVEL, INC. AND SUBSIDIARIES v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 10819-21.

T.C. Memo. 2024-59

PARKWAY GRAVEL, INC. AND SUBSIDIARIES, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed May 21, 2024.

Attorney(s) appearing for the Case

Charles E. Hodges, II and Thomas M. Zaino , for petitioner.

Philip S. Yarberough , Jeannine A. Zabrenski , and Nicole M. Connelly , for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

Respondent determined a deficiency of $1,410,280 and a penalty of $282,056 pursuant to section 6662(a) for 2013. The issues for consideration are whether petitioner engaged in a sham transaction or otherwise assigned income in contravention of the terms of the transaction and...

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