-11-
that an election was not filed with the IRS. Under the
circumstances, we hold that respondent was not obliged to issue
an FSAA to Petito corporation. Consequently, the notice of
deficiency that respondent issued to petitioner is valid.
We shall deny petitioner’s motion to reconsider the Court’s
order denying petitioner’s motion to dismiss. Petitioner failed
to demonstrate that the notice of deficiency in this case is
invalid.
To reflect the foregoing,
An order will be issued
denying petitioner’s Motion
To Reconsider Denial of Motion
To Dismiss.
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Last modified: May 25, 2011