T.C. Memo. 2000-29
UNITED STATES TAX COURT
G.B. DATA SYSTEMS, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 24958-97. Filed January 21, 2000.
William E. Frantz and John E. James, for petitioner.
Nancy C. McCurley, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
CHIECHI, Judge: Respondent determined for the year ended
January 31, 1994, a deficiency in petitioner’s Federal income tax
(tax) in the amount of $399,152 and an addition to tax under
section 6651(a)(1)1 and an accuracy-related penalty under section
1All section references are to the Internal Revenue Code in
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