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MOTOR FUEL CARRIERS, INC. v. COMMISSIONER

Docket No. 3517-74.

34 T.C.M. 1290 (1975)

T.C. Memo. 1975-296

Motor Fuel Carriers, Inc. v. Commissioner.

United States Tax Court.

Filed September 23, 1975.

Attorney(s) appearing for the Case

William R. Frazier, 121 W. Forsyth, Jacksonville Fla., for the petitioner. Robert P. Edler, for the respondent.

Memorandum Findings of Fact and Opinion

QUEALY, Judge:

The respondent determined deficiencies in the income tax of petitioner for the taxable years 1968, 1969, and 1970, in the amounts of $59,226.42, $63,140.24, and $51,490.36, respectively.

The sole issue for decision is whether the petitioner is liable for the surtax under section 5311 for the taxable years in question as having been availed of for the purpose of avoiding...

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