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BURLINGTON NORTHERN RAILROAD v. COMMISSIONER

Docket No. 9867-80.

82 T.C. 143 (1984)

BURLINGTON NORTHERN RAILROAD COMPANY, FORMERLY BURLINGTON NORTHERN INC., SUCCESSOR BY MERGER TO ST. LOUIS-SAN FRANCISCO RAILWAY COMPANY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 24, 1984.

Attorney(s) appearing for the Case

Donald C. Knickerbocker, George A. Morrison, and Steven L. Wood, for the petitioner.

Michael J. Cooper, for the respondent.

OPINION

COHEN, Judge:

In a statutory notice of deficiency dated March 21, 1980, respondent determined deficiencies in petitioner's Federal income taxes for 1974 and 1975 in the amounts of $538,940.21 and $943,047.86, respectively. After concessions, the sole issue for determination is whether petitioner, a calendar year accrual basis taxpayer, may accrue and deduct in 1974 and 1975 the employer's portion of...

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