SCHUYLER GRAIN CO. v. COMMISSIONER

Docket No. 6141-65.

50 T.C. 265 (1968)

SCHUYLER GRAIN COMPANY, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 8, 1968.


Attorney(s) appearing for the Case

Robert E. Johnson, for the petitioner.

Wayne I. Chertow, for the respondent.


WITHEY, Judge:

The respondent determined a deficiency in petitioner's income tax for its fiscal year ended August 31, 1964, in the amount of $2,319.10.

The sole issue presented is whether petitioner's five grain storage bins constructed in the year in question were "used in connection with" any of the activities specified in section 48(a)(1)(B)(i) of the Internal Revenue Code of 1954.1

FINDINGS OF FACT

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