T.C. Memo. 1997-17
UNITED STATES TAX COURT
THE ESCROW CONNECTION, INC., A.K.A. THE ESCROW CONNECTION,
Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15867-94. Filed January 8, 1997.
David Roth, for petitioner.
Patrick W. Lucas, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge: Respondent determined deficiencies in
petitioner's Federal income tax for taxable years ended July 31,
1989 and July 31, 1990, in the amounts of $160,381 and $140,849,
respectively. Respondent also determined an addition to tax of
$40,349 under section 66611 for taxable year ended July 31, 1989,
1 All section references are to the Internal Revenue Code in
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