CONLEE CONSTRUCTION CO. v. COMMISSIONER

Docket No. 1278-67.

54 T.C. 402 (1970)

CONLEE CONSTRUCTION COMPANY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 3, 1970.


Attorney(s) appearing for the Case

Edward A. Kaufman, for the petitioner.

Richard G. Holloway, for the respondent.


OPINION

WITHEY, Judge:

The Commissioner has determined deficiencies in the income tax of petitioner for the following fiscal years ended October 31 in the following respective amounts: 1960, $86,555.92; 1961, $58,224.22; 1962, $71,054.91.

By his motion to dismiss, respondent has raised the issue of the propriety and legality of petitioner's filing of a petition herein under section 6871(b) of the Internal...

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