ROCHESTER DEVELOPMENT CORPORATION v. COMMISSIONER

Docket No. 9070-74.

36 T.C.M. 1213 (1977)

T.C. Memo. 1977-307

Rochester Development Corporation v. Commissioner.

United States Tax Court.

Filed September 12, 1977.


Attorney(s) appearing for the Case

J. Ernest Brophy and Joseph A. Platania, One Exchange St., Rochester, N.Y., for the petitioner. Bernard R. Baker, III, and William J. Neild, for respondent.


Memorandum Findings of Fact and Opinion

TANNENWALD, Judge:

Respondent determined deficiencies in petitioner's Federal income tax as follows:

  Year                Deficiency

  1967 .............. $  1,903.32
  1968 ..............  125,103.66
  1969 ..............  418,868.72

Some of the issues have been disposed of by agreement of the parties, leaving as the sole issue for decision whether payments received by petitioner with...

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