- 2 - compensation for Choate in 1992, as petitioner contends; $265,550, as respondent contends; or some other amount. We hold that petitioner may deduct $1,010,000. Section references are to the Internal Revenue Code as in effect for the relevant periods. Rule references are to the Tax Court Rules of Practice and Procedure. FINDINGS OF FACT Some of the facts have been stipulated and are so found. A. Petitioner Petitioner's principal place of business was in Marietta, Georgia, when it filed the petition in this case. Petitioner is a construction company that specializes in building medical facilities (e.g., operating rooms), biomedical and "clean rooms" for laboratories, highly sophisticated industrial and robotics facilities, and plants that manufacture glass. Businesses use "clean rooms" to manufacture computer chips and pharmaceuticals and for activities that require a sterile environment of up to 100 times cleaner than a hospital operating room. Petitioner's 1992 tax year started on July 1, 1991, and ended on June 30, 1992. Petitioner became an S corporation on July 1, 1993.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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