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GIANNINI PACKING CORP. v. COMMISSIONER

Docket No. 6398-77.

83 T.C. 526 (1984)

GIANNINI PACKING CORPORATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 25, 1984.

Attorney(s) appearing for the Case

John J. McGregor, for the petitioner.

Patricia Anne Golembiewski, for the respondent.

SIMPSON, Judge:

The Commissioner determined deficiencies in the petitioner's Federal income taxes of $10,267.12 for the taxable year ended April 30, 1974, and $8,463.22 for the taxable year ended April 30, 1975. After concessions, the sole issue for decision is whether the structural elements of two rooms in a facility used to cool and preserve fresh fruit are eligible for the investment tax credit under section 38...

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