Cross Oil Company, Inc. - Page 1
















                                 T.C. Memo. 2001-126                                  


                               UNITED STATES TAX COURT                                


                       CROSS OIL COMPANY, INC., Petitioner v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 19154-99.               Filed May 30, 2001.                 


               Paul E. Northcutt, for petitioner.                                     
               Ann L. Darnold, for respondent.                                        

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               COHEN, Judge:  Respondent determined deficiencies of $20,596           
          and $15,803 in petitioner’s Federal income tax for the years                
          ended June 30, 1996, and June 30, 1997, respectively.  The                  
          parties agree that the notice of deficiency contains a                      
          mathematical error in the computation of the section 481 tax                
          amount and that the deficiency in dispute is $15,720 for the tax            
          year ended June 30, 1996.  The sole issue for decision is whether           





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