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FEDDERS CORPORATION AND SUBSIDIARIES v. COMMISSIONER

Docket Nos. 6053-75, 6476-75.

39 T.C.M. 1 (1979)

T.C. Memo. 1979-350

Fedders Corporation and Subsidiaries v. Commissioner. Borg-Warner Corporation v. Commissioner.

United States Tax Court.

Filed September 4, 1979.

Attorney(s) appearing for the Case

Lawrence N. Weiss, for the petitioners in docket No. 6053-75.

Joseph E. McAndrews, Nora A. Bailey, and Neal F. Farrell, for the petitioner in docket No. 6476-75.

Marwin A. Batt, for the respondent.

Memorandum Findings of Fact and Opinion

TANNENWALD, Judge:

Respondent determined the following deficiencies in petitioners' Federal income tax:

Docket No.      Year Ended       Deficiency

 6053-75     August 31, 1968    $7,606,216.89
             August 31, 1969     7,141,349.10
             August 31, 1970       557,506.00
 6476-75     December 31, 1968   6,316,749.57

The primary issue for our decision is the allocation of...

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