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LASTARMCO, INC. v. C.I.R.

No. 83-4370.

737 F.2d 1440 (1984)

LASTARMCO, INC., Petitioner-Appellee, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant.

United States Court of Appeals, Fifth Circuit.

August 6, 1984.

Attorney(s) appearing for the Case

Kenneth W. Gideon, Chief Counsel, John H. Menzel, Director, Tax Lit. Div., Robert B. Miscavich, I.R.S., Glenn L. Archer, Jr., Asst. Atty. Gen., Michael J. Roach, Jonathan S. Cohen, Michael L. Paup, Chief, Appellate Section, Tax Div., U.S. Dept. of Justice, Washington, D.C., for respondent-appellant.

Monroe & Lemann, Richard P. Wolfe, Benjamin B. Blanchet, New Orleans, La., for petitioner-appellee.

Before TATE, and JOLLY, Circuit Judges.

TATE, Circuit Judge:

This appeal concerns the interrelationship and application of several provisions of the Internal Revenue Code of 1954, as amended. The Commissioner appeals from the Tax Court's determination favorable to the taxpayer. 79 T.C. 810 (1982). We affirm.

Overview

For its 1975 tax year, the taxpayer (a corporation) had taxable income (before subtracting the deductions at issue) of $470,980.

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