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MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge: By notices dated December 22, 1994,
respondent determined deficiencies in petitioners' Federal income
taxes as follows:
Kaiser Family Corporation (formerly Kaiser Agency, Inc.), docket
No. 3899-95
Year Deficiency
1990 $28,336
1991 29,237
1992 85,161
William H. (Deceased) and Margaret G. Kaiser, docket No. 3953-95
Year Deficiency
1990 --
1991 --
1992 $127,954
Unless otherwise indicated, all section references are to
the Internal Revenue Code as in effect for the years in issue,
and all Rule references are to the Tax Court Rules of Practice
and Procedure. After concessions, the sole issue for decision is
whether Kaiser Agency, Inc.'s subchapter S election terminated as
a result of excess passive investment income.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. At
the time the petitions were filed, petitioners had mailing
addresses in Rochester, New York.
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