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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