T.C. Memo. 1998-200
UNITED STATES TAX COURT
JRJ EXPRESS INCORPORATED, A CALIFORNIA CORPORATION,
d.b.a. KING EXPRESS INTERNATIONAL, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 21439-96. Filed June 2, 1998.
William E. Crockett, for petitioner.
Marilyn Devin, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge: Respondent determined a $1,008,874 deficiency
in petitioner's Federal income tax for tax year ended April 30,
1993, and a $201,775 section 6662(a) accuracy-related penalty.
All section references are to the Internal Revenue Code in
effect for the year in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
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