T.C. Memo. 1997-130
UNITED STATES TAX COURT
SPENCER MEDICAL ASSOCIATES, AUTOMOTIVE VENTURES, INC. F/K/A
SPENCER TOYOTA, INC., TAX MATTERS PARTNER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 17212-95. Filed March 12, 1997.
D. Christopher Ohly and Kevin F. Leahy, for petitioner.
Karen E. Chandler, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Chief Judge: By Notice of Final Partnership
Administrative Adjustment (FPAA) dated June 6, 1995, respondent
determined an upward adjustment in Spencer Medical Associates'
ordinary income for 1990 in the amount of $1,084,547. Unless
otherwise indicated, all section references are to the Internal
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