- 5 -
was granted S corporation status. For the tax period ending
December 31, 1987, and the tax year ending December 31, 1988, ABC
was a non-TEFRA subchapter S corporation, and all of ABC's
adjustments flowed through to its sole shareholder, John P.
Parsons, and are reflected in the deficiencies shown in docket
No. 20691-91.
On January 27, 1992, these cases were consolidated. These
consolidated cases were submitted without a trial pursuant to
Rule 122.
At the time the petitions were filed in these cases,
Guaranteed and ABC (hereinafter sometimes collectively referred
to as the Entities or individually referred to as an Entity) were
corporations incorporated in the State of Texas with their
principal offices located in Wichita, Kansas. During the taxable
periods in controversy, Guaranteed and ABC were accrual basis
taxpayers.
For the fiscal year ending May 31, 1987, ABC timely filed
its Federal corporate income tax return. ABC timely filed a
valid subchapter S election, and the election was granted
effective June 1, 1987. Guaranteed timely filed its Federal
corporate income tax return for an S corporation for the calendar
year ending 1987, and ABC timely filed its Federal corporate
income tax return for an S corporation for the short taxable
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