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GOLDEN GATE DISPOSAL COMPANY v. COMMISSIONER

Docket Nos. 10802-76, 10803-76.

38 T.C.M. 835 (1979)

T.C. Memo. 1979-199

Golden Gate Disposal Company, West Coast Salvage Company, Western Container Company, and Macor Incorporated v. Commissioner. Sunset Scavenger Company v. Commissioner.

United States Tax Court.

Filed May 21, 1979.

Attorney(s) appearing for the Case

Charles A. Lane, 234 Front St., San Francisco, Calif., for the petitioners. Eugene H. Ciranni, for the respondent.

Memorandum Findings of Fact and Opinion

WILES, Judge:

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

Docket No.         Fiscal Year        Deficiency

  10802-76 ..... September 30, 1972   $231.084.48
  10803-76 ..... September 30, 1972    260,025.84

We must decide whether petitioners are entitled to either an abandonment or retirement loss deduction under section 165(a)

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