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The Form 2553 contained the following information: JPS's
name and address, the principal business activity of JPS, the
number of shares issued, the name of a predecessor business
("Johnson Programming Services"), the date and place of
incorporation ("10-25-76 California"), and three signatures, one
apparently the signature of petitioner as president, and the
other two apparently the signatures of petitioner and Mary Ann
Johnson as shareholders consenting to the election. The parties
have stipulated that in the opinion of respondent's handwriting
expert, there is a high degree of probability that the apparent
signature of petitioner as president of JPS is a traced
signature, and the apparent signature of petitioner as
shareholder is a simulated signature. The parties have
stipulated that if Mary Ann Johnson were called to testify, she
would testify that the apparent signature of Mary Ann Johnson on
the Form 2553 does not appear to her to be her signature.
On January 7, 1977, the Fresno Service Center sent a letter
accompanied by the original Form 2553 described above. The
letter was addressed to JPS at the address listed on the Form
2553 and informed the recipient that the Form 2553 could not be
processed because the following information was missing: The
date JPS first had shareholders; the date JPS first had assets;
the date JPS began doing business; the last month of the taxable
year for which JPS's annual return would be filed; and for each
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Last modified: May 25, 2011