Southern Boiler Sales & Service, Inc. - Page 1

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          T.C. Memo. 1996-13                                                          


                               UNITED STATES TAX COURT                                


                SOUTHERN BOILER SALES & SERVICE, INC., Petitioner v.                  
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 18272-93.             Filed January 22, 1996.               



               Mathew E. Bates, for petitioner.                                       
               Amy Dyar Seals, for respondent.                                        


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               PARKER, Judge:  Respondent determined deficiencies in                  
          petitioner's corporate Federal income tax and an addition to tax            
          and penalty as follows:                                                     
          Taxable Year                 Addition to Tax   Penalty                      
             Ending       Deficiency     Sec. 6653(a)   Sec. 6662                     
          7-31-89        $12,363         $618          --                             
          7-31-90         21,571          --         $4,314