Charles C. Allen, III and Barbara N. Allen v. Commissioner

118 T.C. No. 1

UNITED STATES TAX COURT CHARLES C. ALLEN, III AND BARBARA N. ALLEN, ET AL.,1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 1287-00, 1288-00, Filed January 4, 2002. 1289-00, 1290-00, 1291-00, 1292-00, 1293-00, 1618-00. Ps are the shareholders of F, a subch. S corporation. During its 1994 and 1995 taxable years, F incurred wages that qualified for the targeted jobs credit (TJC) under secs. 38 and 51, I.R.C. F claimed TJCs of $456,264 and $259,434 for the respective years and reported to Ps their proportionate shares of the credits. F reduced its deduction…