T.C. Memo. 2008-62 UNITED STATES TAX COURT NEW YORK GUANGDONG FINANCE, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 14809-04. Filed March 11, 2008. Larry Kars, for petitioner. Joseph W. Fogelson and Nicole F. Cammarota, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION MARVEL, Judge: By a notice of deficiency dated May 25, 2004, respondent determined the following withholding tax deficiencies and additions to tax against petitioner:1 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and (continued...)Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008