RHOADES OIL COMPANY v. COMMISSIONER

Docket Nos. 4926-78, 17287-79.

50 T.C.M. 294 (1985)

T.C. Memo. 1985-322

Rhoades Oil Company, Petitioner v. Commissioner of Internal Revenue, Respondent.

United States Tax Court.

Filed July 1, 1985.


Attorney(s) appearing for the Case

William C. Jones, III, for the petitioner. Charles N. Woodward, for the respondent.


Memorandum Findings of Fact and Opinion

PARKER, Judge:

In these consolidated cases, respondent determined deficiencies in petitioner's corporate income tax as follows:

     Docket No.     Year     Deficiency

      4926-78       1974      $274,875
      17287-79      1975       205,613
                    1976       132,147

The sole issue1 for decision is whether petitioner was availed of during its...

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