T.C. Memo. 2001-145
UNITED STATES TAX COURT
SMARTHEALTH, INC., f.k.a. SEMANTODONTICS, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8048-99. Filed June 20, 2001.
Jeffrey N. Kelm, Denton N. Thomas, and Dennis I. Leonard,
for petitioner.
David A. Winsten and J. Robert Cuatto, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge: Respondent determined deficiencies in
petitioner’s Federal income taxes of $306,731 and $80,346 for
the taxable years ending May 31, 1995, and May 31, 1996,
respectively. The sole issue for decision is whether amounts
which petitioner received from its customers in excess of the
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