Reed-Merrill, Inc. - Page 1

                                       T.C. Memo. 2000-215                                             

                                     UNITED STATES TAX COURT                                           

                               REED-MERRILL, INC., Petitioner v.                                       
                        COMMISSIONER OF INTERNAL REVENUE, Respondent                                   

                  Docket No. 10494-98.                    Filed July 17, 2000.                         

                  Kandace C. Gerdes, for petitioner.                                                   
                  Joel A. Lopata, for respondent.                                                      

                           MEMORANDUM FINDINGS OF FACT AND OPINION                                     

                  FOLEY, Judge:  By notice dated March 9, 1998, respondent                             
            determined deficiencies of $23,938 and $92,548, and penalties,                             
            pursuant to section 6662(a), of $4,787.60 and $18,509.60,                                  
            relating to petitioner’s 1993 and 1994 Federal income taxes,                               
            respectively.  Unless otherwise indicated, all section references                          
            are to the Internal Revenue Code in effect for the years in                                

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