T.C. Memo. 1996-280
UNITED STATES TAX COURT
APOLLO OVERSEAS INTERNATIONAL, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5031-94. Filed June 17, 1996.
James S. Yan, for petitioner.
Clifton B. Cates III and Nancy C. McCurley, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
SCOTT, Judge: Respondent determined deficiencies in
petitioner's Federal income taxes and additions to tax for the
taxable years ended January 31, 1988, 1989, and 1990, as follows:
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