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CONCORD CONTROL, INC. v. C. I. R.

Nos. 77-1581, 77-1582.

615 F.2d 1153 (1980)

CONCORD CONTROL, INC., Petitioner-Appellant, Cross-Appellee, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee, Cross-Appellant.

United States Court of Appeals, Sixth Circuit.

Decided February 25, 1980.

Attorney(s) appearing for the Case

Michael I. Saltzman, New York City, for Concord Control, Inc.

M. Carr Ferguson, Gary Allen, Timothy McBride, Asst. Attys. Gen., Gilbert E. Andrews, Tax Division, Dept. of Justice, Stewart E. Seigel, Chief Counsel, I.R.S., Washington, D.C., for Com'r of Internal Revenue.

Before BROWN, KENNEDY and JONES, Circuit Judges.

NATHANIEL R. JONES, Circuit Judge.

The Commissioner of Internal Revenue assessed Concord Control, Inc. with a tax deficiency totaling $481,552.00 for the time period between February 18, 1964 and November 30, 1966. Concord Control petitioned the United States Tax Court for a redetermination of the deficiency, claiming that no deficiency was due. The Tax Court calculated a deficiency of $258,177.00, finding partly in favor of Concord Control and partly in favor of...

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