T.C. Memo. 1996-316
UNITED STATES TAX COURT
LEONARD PIPELINE CONTRACTORS, LTD., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 28985-91. Filed July 15, 1996.
Marc L. Spitzer and James P. Powers, for petitioner.
Susan E. Seabrook, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge: Leonard Pipeline Contractors, Ltd. petitioned
the Court to redetermine respondent’s determination of an $807,983
deficiency in its income tax for its taxable year ended September
30, 1987, and additions to tax pursuant to section 6653(a)(1)(A) in
the amount of $40,399 and section 6653(a)(1)(B) in the amount of 50
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