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employee hours were spent on investment services.
Because 80.53 percent is less than 95 percent, Lykins Inc.
was not a QPSC in 2000, and so not subject to tax at the QPSC
rate used in the notice of deficiency. The Commissioner’s
assertion of a penalty disappears with that deficiency, and so
Decision will be entered
for petitioner.
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Last modified: May 25, 2011