Sheryl D. Bumpus - Page 8




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               Having elected to conduct the business in corporate form,              
          petitioner is bound by the Federal income tax consequences of               
          that election.  See Higgins v. Smith, 308 U.S. 473 (1940).                  
          Drywall's corporate existence cannot be disregarded for Federal             
          income tax purposes, and petitioner's argument that it should be            
          is rejected.  Because the lease cancellation fee was an expense             
          of Drywall, petitioner is not entitled to include the payment of            
          the fee in the rent expense deduction claimed on her return.                
          Respondent's determination in this regard is sustained.                     
               To reflect the foregoing and the concessions of the parties,           
                                             Decision will be entered                 
                                        under Rule 155.                               



























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