George Johnson, Jr. - Page 2

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            briefs and memoranda in support of and in opposition to these                             
            motions.  Respondent determined the following deficiencies in,                            
            and additions to, petitioner's1 Federal income taxes:                                     
                                                      Addition to Tax                                 
                  Year              Deficiency              Sec. 6653(b)                              
                  1979              $50,487.36              $25,243.68                                
                  1980              52,617.33               26,308.67                                 

                  Unless otherwise noted, 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.  For taxable year 1979, respondent determined a total                          
            adjustment to income of $130,930.37, of which $122,975.37 was                             
            attributed to undistributed taxable income from Johnson                                   
            Programming Services, Inc. (JPS).  For taxable year 1980,                                 
            respondent determined a total adjustment to income of                                     
            $105,430.17, of which $58,602.34 was attributed to undistributed                          
            taxable income from JPS.  Petitioner's motion requests the Court                          
            to rule as a matter of law that JPS was not a corporation taxable                         
            under subchapter S of the Internal Revenue Code (S corporation).                          
            Respondent's cross-motion requests the Court to rule as a matter                          



                  1 In the notice of deficiency, respondent also determined                           
            the deficiencies (but not the additions to tax) against                                   
            petitioner's wife at the time, Mary Ann Johnson.  Respondent has                          
            agreed that Mary Ann Johnson qualifies as an innocent spouse, and                         
            she is not a petitioner in this case.                                                     




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