T.C. Memo. 2007-140
UNITED STATES TAX COURT
CALPO HOM & DONG ARCHITECTS, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4227-05. Filed June 4, 2007.
Richard Todd Luoma, for petitioner.
Christian A. Speck, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
HAINES, Judge: Respondent determined a deficiency of $7,506
in petitioner’s 2002 Federal corporate income tax. The issue for
decision is whether, during 2002, petitioner was a qualified
personal service corporation as defined by section 448(d)(2).1
1 Unless otherwise indicated, all section references are to
(continued...)
Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: November 10, 2007