On Shore Quality Control Specialist, Inc. - Page 1

                                 T.C. Memo. 1996-95                                   

                               UNITED STATES TAX COURT                                

                ON SHORE QUALITY CONTROL SPECIALIST, INC., Petitioner                 
                   v. COMMISSIONER OF INTERNAL REVENUE, Respondent                    

               Docket No. 7496-94.               Filed March 4, 1996.                 

               Harry E. Caylor III (an officer), for petitioner.                      
               Joni D. Larson, for respondent.                                        

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               POWELL, Special Trial Judge:  This case was assigned                   
          pursuant to the provisions of section 7443A(b)(4) and Rules 180,            
          181, and 183.1                                                              
               Respondent determined deficiencies in petitioner's Federal             
          income taxes for the fiscal years ending August 31, 1991 and                

          1   All section references are to the Internal Revenue Code                 
          in effect for the years in issue, and all Rule references are to            
          the Tax Court Rules of Practice and Procedure, unless otherwise             

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