Michael E. and Linda S. Murray - Page 5




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            filed a tax return with the Commissioner in September 1995,                                
            reporting that on December 31, 1993, it owned no assets, owed no                           
            liabilities, and had a retained deficit of $1,000.  Cf. Beatty v.                          
            Commissioner, 106 T.C. 268, 273 n.5 (1996), and the cases cited                            
            therein.  We hold for respondent.                                                          
                  To reflect concessions,                                                              
                                                            Decision will be entered                   
                                                      under Rule 155.                                  

































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