KATES HOLDING CO. v. COMMISSIONER

Docket No. 4397-80.

79 T.C. 700 (1982)

KATES HOLDING CO., INC. (FORMERLY CRESTLINE INDUSTRIES CORPORATION, A CORPORATION OF THE COMMONWEALTH OF PENNSYLVANIA), PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 28, 1982.


Attorney(s) appearing for the Case

Robert B. Haines and Timothy Boderck, for the petitioner.

Andrew I. Panken and Patrick E. Whelan, for the respondent.


SHIELDS, Judge:

Respondent determined a liability in petitioner's Federal income taxes, due to its status as a transferee, in the amount of $49,016 for the taxable year ending June 30, 1974. Due to concessions by petitioner, the sole issue involved is whether petitioner's transferor qualified for a special deduction under section 922(a)1 as a Western Hemisphere trade corporation. In particular...

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