NOT FOR PUBLICATION WITHOUT APPROVAL OF THE TAX COURT COMMITTEE ON OPINIONS CIMINO , J.T.C. INTRODUCTION In this matter, the corporation, Charley O's, was audited and additional Corporation Business Tax and Sales and Use Tax liability was assessed. The individual plaintiff taxpayers, William and Patricia McCormick were then assessed for additional Gross Income Tax based upon the Charley O's audit. The McCormicks are shareholders of Charley O's. Charley O's timely appealed the assessment...