G.B. Data Systems, Inc. - Page 1

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                                  T.C. Memo. 2000-29                                    


                                UNITED STATES TAX COURT                                 


                        G.B. DATA SYSTEMS, INC., Petitioner v.                          
                     COMMISSIONER OF INTERNAL REVENUE, Respondent                       


               Docket No. 24958-97.           Filed January 21, 2000.                   


               William E. Frantz and John E. James, for petitioner.                     
               Nancy C. McCurley, for respondent.                                       


                       MEMORANDUM FINDINGS OF FACT AND OPINION                          

               CHIECHI, Judge:  Respondent determined for the year ended                
          January 31, 1994, a deficiency in petitioner’s Federal income tax             
          (tax) in the amount of $399,152 and an addition to tax under                  
          section 6651(a)(1)1 and an accuracy-related penalty under section             


               1All section references are to the Internal Revenue Code in              
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