Door Control Services, Inc., et al., (1996)

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Door Control Services, Inc., et al., (1996)

T.C. Memo. 1996-508

UNITED STATES TAX COURT DOOR CONTROL SERVICES, INC., ET AL.,1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 9936-94, 10132-94, Filed November 14, 1996.

10140-94.

J. W. Tyner, for petitioners. Stephen C. Coen, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION FOLEY, Judge: By notices of deficiency dated March 16, 1994, respondent determined the following deficiencies and additions to tax with respect to petitioners' Federal income taxes:

Jimmy Don and Sharon L. Gilchrist, docket No. 10132-94

Additions to Tax Year Deficiency Sec. 6653(b)(1)(A) Sec. 6653(b)(1)(B) Sec. 6653(b)(1) Sec. 6661

1986 $34,608 $25,956 1 -- $8,652 1987 23,644 17,733 2 -- 5,911 1988 38,316 -- -- $28,737 9,579

Gilchrist resided, and Door Control Services, Inc., had its principal place of business, in Ben Wheeler, Texas.

In 1973, the Gilchrists entered into the business of servicing automatic do...

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