- 14 -
Our disposition of the case on this ground makes it
unnecessary for us to address whether AA&H was an entity such as
a partnership or corporation, or the extent of Mr. Aydin's
ownership interest in it. We therefore need not consider whether
AA&H was a foreign entity, so as to bring section 267(a)(3) into
play.
For the foregoing reasons,
An appropriate order and
decision will be entered for
respondent.
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