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.Page: 1 2 3 4 5 6 7 Next
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