Colorado Gas Compression, Inc. - Page 1
















                                   116 T.C. No. 1                                     


                               UNITED STATES TAX COURT                                


                    COLORADO GAS COMPRESSION, INC., Petitioner v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 17251-98.                  Filed January 2, 2001.           

                    P became an S corp. in 1988, a C corp. in 1989,                   
               and an S corp. in 1994.  In 1994, 1995, and 1996,                      
               petitioner sold assets which had accrued gain prior to                 
               the 1994 conversion from C to S corp. status.                          
                    Held:  The transition rule of sec. 633(d) of the                  
               Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2278,                
               relating to a corp. which, pursuant to its most recent                 
               election, became an S corp. before 1989, is not                        
               applicable to P’s 1994, 1995, and 1996 taxable years.                  

               Carl Garold Sims, for petitioner.                                      
               Frederick J. Lockhart, Jr., for respondent.                            











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