BENNETT PAPER CORP. v. COMMISSIONER

Docket No. 9854-78.

78 T.C. 458 (1982)

BENNETT PAPER CORPORATION AND SUBSIDIARIES, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 29, 1982.


Attorney(s) appearing for the Case

Donald H. Whaley, for the petitioners.

William J. Falk, for the respondent.


WILES, Judge:

Respondent determined a deficiency of $93,895 in petitioners' 1974 Federal income tax. After concessions, the issues for decision are:

(1) Whether certain preopening expenditures claimed on petitioners' consolidated return were incurred in the course of a trade or business under section 162(a).1

(2) Whether petitioners are entitled to a deduction in excess of...

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