New York Football Giants, Inc. - Page 1

                                   117 T.C. No. 15                                    

                               UNITED STATES TAX COURT                                

                    NEW YORK FOOTBALL GIANTS, INC., Petitioner v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 8563-00.                  Filed October 30, 2001.           

                    Respondent (R) sent petitioner (P), an S                          
               corporation, a notice of deficiency in which R                         
               determined that P was subject to the built-in gains tax                
               under sec. 1374, I.R.C., for payments P received in                    
               fiscal years 1996, 1997, and 1998.  R issued no notice                 
               of final S corporation administrative adjustment to P                  
               for fiscal years 1996 or 1997.                                         
                    R contends that the notice of deficiency is                       
               invalid as to fiscal years 1996 and 1997 and prohibited                
               by secs. 6225 and 6244, I.R.C., for those years because                
               the built-in gains tax is a subchapter S item, sec.                    
               301.6245-1T, Temporary Proced. & Admin. Regs., 52 Fed.                 
               Reg. 3003 (Jan. 30, 1987), that must be determined in a                
               unified audit and litigation procedure for an S                        
                    P contends that the built-in gains tax is not a                   
               subchapter S item and that sec. 301.6245-1T, Temporary                 
               Proced. & Admin. Regs., is invalid.                                    

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