T.C. Memo. 2001-19
UNITED STATES TAX COURT
KNIGHT FURNITURE CO., INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15369-99. Filed January 29, 2001.
Samuel W. Graber and Jason W. Richardson, for petitioner.
James F. Prothro, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge: Respondent determined deficiencies of
$94,876, $75,398, and $62,569 in petitioner’s Federal income tax
for 1995, 1996, and 1997, respectively. The sole issue for
decision is whether, for each of the years in issue, petitioner
was a corporation described in section 532, i.e., a corporation
availed of for the purpose of avoiding income tax with respect to
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