ABC Rentals of San Antonio, Inc., et al - Page 4

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          John P. Parsons and Melba R. Parsons--Docket No. 20691-91                   
                                                  Additions to Tax                    
          Tax Period Ended         Deficiency        Sec. 6661                        
               12/31/87            $11,028             $2,757                         
               12/31/88            8,095               2,024                          
               Respondent subsequently conceded the additions to tax                  
          pursuant to section 6661 in docket No. 20691-91 for the 1987 and            
          1988 taxable years in the amounts of $2,757 and $2,024,                     
          respectively.                                                               
               During the tax periods in issue, Guaranteed Rental Systems,            
          Inc. (Guaranteed), was an S corporation not subject to the                  
          unified audit and litigation procedures of the Tax Equity and               
          Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, sec.             
          402(a), 96 Stat. 324, 648,3 and all of Guaranteed's adjustments             
          flowed directly through to the shareholders' tax returns and are            
          reflected in the deficiencies shown in docket Nos. 20690-91 and             
          20691-91.  For the fiscal year ending May 31, 1987, ABC Rentals             
          of San Antonio, Inc. (ABC), was a C corporation, and the notice             
          of deficiency in docket No. 20689-91 relates to deficiencies                
          during that fiscal year only.  Thereafter, ABC applied for and              

               3Sec. 6244 provides that the TEFRA provisions relating to              
          the assessment and determination of partnership items are                   
          extended to the assessment and determination of subch. S items.             
          Sec. 301.6241-1T(c), Temporary Proced. & Admin. Regs., 52 Fed.              
          Reg. 3003 (Jan. 30, 1987), exempts small S corporations, defined            
          as corporations with 5 or fewer shareholders, from the unified              
          audit and litigation procedures for taxable years the due date of           
          the return of which is on or after Jan. 30, 1987.                           





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