F.D. RICH CO., INCORPORATED v. COMMISSIONER

Docket No. 9007-74.

36 T.C.M. 546 (1977)

T.C. Memo. 1977-125

F.D. Rich Co., Incorporated v. Commissioner.

United States Tax Court.

Filed May 2, 1977.


Attorney(s) appearing for the Case

Lawrence Gochberg (an officer), One Landmark Sq., 101 Broad St., Stamford, Conn., for the petitioner. Robert S. Walker, for the respondent.


Memorandum Findings of Fact and Opinion

FAY, Judge:

Respondent determined a deficiency of $115,437.78 in petitioner's Federal income tax for the fiscal year ended September 30, 1963. This deficiency occurred as a result of respondent's disallowance of a tentative loss caryback from the fiscal year ended September 30, 1966. We are to decide whether certain income received by petitioner from a long-term contract is reportable in the year ended September 30...

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