T.C. Memo. 2001-119
UNITED STATES TAX COURT
METRO LEASING AND DEVELOPMENT CORPORATION, EAST BAY
CHEVROLET COMPANY, A CORPORATION, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 8054-99, 8055-99. Filed May 18, 2001.
William L. Raby, for petitioners.
Kathryn K. Vetter, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge: In these consolidated cases, respondent
determined the following deficiencies and penalties in
petitioners’1 1995 and 1996 taxable years:
1 Petitioner, Metro Leasing and Development Corp. is a
successor in interest to petitioner, East Bay Chevrolet Co., a
corporation. Accordingly, there is no need to distinguish
between them for purposes of this opinion, and petitioners will
be collectively referred to as petitioner.
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