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EPIC METALS CORPORATION AND SUBSIDIARIES v. COMMISSIONER

Docket No. 2689-79.

48 T.C.M. 357 (1984)

T.C. Memo. 1984-322

Epic Metals Corporation and Subsidiaries v. Commissioner.

United States Tax Court.

Filed June 25, 1984.

Attorney(s) appearing for the Case

Lester A. Katz, Herbert Alan Dubin, and Gerard J. Mene, 818 Connecticut Ave. N.W., Wash. D.C., for the petitioner. Kathleen E. Whatley, for the respondent.

Memorandum Opinion

SIMPSON, Judge:

The Commissioner determined deficiencies in the petitioner's Federal income tax of $786,165 for the taxable year ended March 31, 1974, and $6,414 for the taxable year ended March 31, 1976. After concessions by the petitioner, the issues for decision are: Whether Epic Sales Corporation is required by sections 446 and 471 of the Internal Revenue Code of 19541 and the regulations promulgated thereunder...

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