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
Last modified: May 25, 2011