T.C. Memo. 1999-242
UNITED STATES TAX COURT
UNICO SALES & MARKETING, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1484-98. Filed July 23, 1999.
Fred A. Foley, for petitioner.
Eric R. Skinner, for respondent.
MEMORANDUM OPINION
LARO, Judge: The parties submitted this case to the Court
without trial. See Rule 122. Petitioner petitioned the Court on
January 26, 1998, to redetermine respondent's determination of
deficiencies in petitioner's Federal income tax for fiscal years
ended April 30, 1990 and 1991. Respondent determined petitioner
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