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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