Ohio Periodical Distributors, Inc., f.k.a. Scott Krauss News Agency, Inc., Ronald E. Scherer Trust and Linda S. Hayner Trust, Persons Other Than the Tax Matters Person - Page 1

                                       T.C. Memo. 1995-496                                            

                                     UNITED STATES TAX COURT                                          

                  OHIO PERIODICAL DISTRIBUTORS, INC., f.k.a. SCOTT KRAUSS                             
                       NEWS AGENCY, INC., RONALD E. SCHERER TRUST AND                                 
                        LINDA S. HAYNER TRUST, PERSONS OTHER THAN THE                                 
                              TAX MATTERS PERSON, Petitioners v.                                      
                        COMMISSIONER OF INTERNAL REVENUE, Respondent                                  

                  Docket No. 12982-94.                Filed October 16, 1995.                         

                  Daniel M. Davidson, for petitioners.                                                
                  James E. Kagy, for respondent.                                                      

                                        MEMORANDUM OPINION                                            

                  RAUM, Judge:  The Commissioner determined adjustments in the                        
            S corporation's income in the amounts of $3,869,422, ($101,725),                          
            $165,516, and $464,205 for its taxable years 1985, 1986, 1987,                            
            and 1988, respectively.  At issue is whether an election made by                          

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