T.C. Memo. 1997-124
UNITED STATES TAX COURT
CHARLOTTE AIRCRAFT CORPORATION AND SUBSIDIARIES, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2582-96. Filed March 11, 1997.
G. Edward Hinshaw, Jr. and W. Curtis Elliott, Jr., for
petitioner.
Frank C. McClanahan III, for respondent.
MEMORANDUM OPINION
HAMBLEN, Judge: This matter is before the Court on
petitioner's motion for partial summary judgment. Unless
otherwise indicated, all section references are to the Internal
Revenue Code in effect for the taxable years at issue, and all
Rule references are to the Tax Court Rules of Practice and
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