T.C. Memo. 1996-563
UNITED STATES TAX COURT
SUMMIT SHEET METAL CO., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 20131-93. Filed December 30, 1996.
Elliott H. Kajan and Steven R. Mather, for petitioner.
Lisa W. Kuo and T. Elizabeth Stetson, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge: Respondent determined a deficiency in
petitioner's Federal income tax of $307,671 for 1987.
Petitioner is an S corporation. An S corporation is liable
for tax on net recognized built-in gain if that gain exceeds 50
percent of its taxable income for the year in issue. Sec.
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