-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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11
Last modified: May 25, 2011