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Respondent filed a Notice of Objection to Petitioner’s Motion for
Partial Summary Judgment and Respondent’s Memorandum of
Authorities. Petitioner filed Petitioner’s Reply to Respondent’s
Notice of Objection to Petitioner’s Motion for Partial Summary
Judgment. As explained more fully below, we will deny
petitioner’s Motion for Partial Summary Judgment.
Background
By a notice of deficiency mailed to petitioner on July 1,
1998, respondent determined deficiencies in Federal income taxes
due from petitioner for the fiscal years ended February 28, 1993
and 1994 in the amounts of $217,280 and $126,017, respectively.
Petitioner timely filed a petition in this case on February
19, 1999, and respondent timely answered on April 12, 1999.
Limited Gaming of America, Inc., hereinafter referred to as
LGA or petitioner, is a Colorado corporation originally formed on
May 5, 1991. LGA is a “C” corporation; it has a fiscal year
ending on February 28.
On or about January 4, 1994, LGA caused to be formed Sunrise
Island Timber Company, hereinafter referred to as Sunrise, a
Florida general partnership, for the purpose of holding real
property consisting of an island located in the Mississippi
River. Sunrise was subsequently converted to a Florida limited
partnership in February 1995.
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