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
indicated.
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