T.C. Memo. 1997-332 UNITED STATES TAX COURT PRIMCO MANAGEMENT COMPANY, ALFRED DREYFUS GOLDMAN REVOCABLE LIVING TRUST, ALFRED D. GOLDMAN, FIDUCIARY, TAX MATTERS PERSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13146-96. Filed July 23, 1997. Clarke Lewis Randall, for petitioner. William A. Heard III, for respondent. MEMORANDUM OPINION ARMEN, Special Trial Judge: This matter is before the Court on petitioner's Motion to Dismiss for Lack of Jurisdiction. The issue to be decided is whether an S corporation, whose sole shareholders are two grantor trusts, constitutes a "small S corporation" within the meaning of section 301.6241-1T(c)(2),Page: 1 2 3 4 5 6 7 8 9 10 Next
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