T.C. Memo. 1996-21
UNITED STATES TAX COURT
HERITAGE AUTO CENTER, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 26362-92. Filed January 23, 1996.
Patricia Tucker, for petitioner.
Thomas F. Eagan, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
PARR, Judge: Respondent determined deficiencies in
petitioner's Federal income tax for 1988 and 1989 of $482 and
$213,139, respectively. By amended answer, respondent asserted
increased deficiencies for 1988 and 1989 of $78,277 and $31,929,
respectively. Thus, the total deficiencies asserted by
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