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H. C. COCKRELL WAREHOUSE CORP. v. COMMISSIONER

Docket No. 7260-76.

71 T.C. 1036 (1979)

H. C. COCKRELL WAREHOUSE CORPORATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 26, 1979.

Attorney(s) appearing for the Case

Carle E. Davis and Joseph C. Wool, Jr., for the petitioner.

John C. McDougal, for the respondent.

DRENNEN, Judge:

Respondent determined deficiencies in petitioner's income tax of $6,974.78 and $6,521.81 for the respective taxable years ending June 30, 1972, and June 30, 1973. Some adjustments determined by respondent have not been contested. The central issue before us is whether under section 532(a), I.R.C. 1954,1 petitioner was formed or availed of during the fiscal years 1972 and 1973 for the purpose of avoiding the income...

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