Maritime Grain and Trading, Limited - Page 1

                                 T.C. Memo. 1999-322                                  

                               UNITED STATES TAX COURT                                

                 MARITIME GRAIN AND TRADING, LIMITED, Petitioner v.                   
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 23181-97.               Filed September 24, 1999.           

               Mehdi Gerami (an officer), for petitioner.                             
               Nancy C. McCurley, for respondent.                                     

                                 MEMORANDUM OPINION                                   

               CHIECHI, Judge:  Respondent determined the following                   
          deficiencies in, and accuracy-related penalties under section               
          6662(a)1 on, petitioner's Federal income tax:                               

               1All section references are to the Internal Revenue Code in            
          effect for the years at issue.  All Rule references are to the              
          Tax Court Rules of Practice and Procedure.                                  

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