Primco Management Company, Alfred Dreyfus Goldman Revocable Living Trust, Alfred D. Goldman, Fiduciary, Tax Matters Person - Page 10

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          if any shareholder in the corporation during that taxable year is           
          a pass-through shareholder; i.e., a trust, nominee, or similar              
          pass-through person.  Because Primco's sole shareholders during             
          the years in issue were two grantor trusts, we hold that Primco             
          does not qualify under the small S corporation exception to the             
          unified S corporation audit and litigation procedures, section              
          301.6241-1T(c)(2), Temporary Proced. & Admin. Regs., and,                   
          therefore, that the FSAA issued to Primco is valid.                         
          Consequently, we shall deny petitioner's Motion to Dismiss for              
          Lack of Jurisdiction.                                                       
               To reflect the foregoing,                                              
                                             An order will be issued                  
                                        denying petitioner's Motion to                
                                        Dismiss for Lack of Jurisdiction.             






















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