T.C. Memo. 1995-539
UNITED STATES TAX COURT
GUY SCHOENECKER, INC., BUSINESS INCENTIVES, INC.,
AND CAROUSEL BY GUY, INC., Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 11462-93, 1268-94. Filed November 14, 1995.
James E. O'Brien and Wayne A. Hergott, for petitioners in
docket Nos. 11462-93 and 1268-94.
Steven Z. Kaplan, for petitioners in docket No. 11462-93.
Genelle F. Forsberg, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
SCOTT, Judge: Respondent determined deficiencies in the
consolidated income tax of Guy Schoenecker, Inc., and its two
subsidiaries for the years and in the amounts as follows:
Fiscal year ended Deficiency
June 30, 1988 $254,535
June 30, 1989 587,024
June 30, 1990 1,305,103
June 30, 1991 82,587
All section references are to the Internal Revenue Code in
effect for the years in issue, and all Rule references are to the
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