Jim Turin & Sons, Inc. - Page 1

                                 T.C. Memo. 1998-223                                  


                               UNITED STATES TAX COURT                                


                        JIM TURIN & SONS, INC., Petitioner v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 17643-96.                    Filed June 24, 1998.           


               Norman Sepenuk and Gary P. Compa, for petitioner.                      
               Kathey I. Shaw and Shirley M. Francis, for respondent.                 


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               PARR, Judge:   Respondent determined deficiencies in                   
          petitioner's Federal income tax for taxable years 1987, 1988,               
          1990, 1991, and 1993 in the amounts of $378, $302, $23,269,                 
          $39,561, and $20,770, respectively.                                         
               All section references are to the Internal Revenue Code in             
          effect for the taxable years in issue, and all Rule references              





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