Carroll McEntee & McGinley, Inc. v. Department of Finance

The gravamen of the dispute between the parties is whether petitioner is entitled to a subsidiary capital election or whether, as respondent claims, the election is invalid and it is entitled to collect a tax deficiency of $478,768.38 for the year ended December 31, 1981, as claimed in a notice of determination issued in April 1983. In June 1983, petitioner requested a hearing in order to dispute the deficiency assessment. Due in part to an ensuing audit, which took three years to complete, and to a further two-year delay in scheduling a hearing, the matter languished until the latter part of…