Miller v. United States

ORDER

HAROLD L. MURPHY, District Judge.

Charles D. Miller is a shareholder of Multitex Corporation of America (Multitex). Multitex is an “S corporation” and, for the years 1983, 1984 and 1985, Multitex reported its operations for income tax purposes by passing its tax consequences through to its three shareholders and paying taxes at the shareholder level.

In 1988, the Tax Commissioner mailed a Notice of Final S Corporation Administrative Adjustment (FSAA) to Miller for the years 1983, 1984 and 1985. The Commissioner issued the FSAA because he found that Miller’s tax liability as a Multitex…