Colorado Gas Compression, Inc. v. Commissioner

HOLLOWAY, Circuit Judge.

The IRS determined that petitioner/appellant Colorado Gas Compression, Inc. owed additional taxes totaling over $900,000 for the years 1994,1995 and 1996. Colorado Gas filed a petition in the United States Tax Court to contest the notice of deficiency in 1998. The parties stipulated to all material facts and submitted the matter to the Tax Court for its decision. The Tax Court rejected the arguments of Colorado Gas, 116 T.C. 1, 2001 WL 6009 (2001), and entered a decision reflecting revised determinations which set the total deficiencies for the three tax years at just…