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PECHINEY UGINE KUHLMANN CORP. AND SUBSIDIARY v. COMMISSIONER

Docket No. 276-81.

51 T.C.M. 1210 (1986)

T.C. Memo. 1986-244

Pechiney Ugine Kuhlmann Corp. and Subsidiary (Formerly: Pechiney Enterprises, Incorporated and Subsidiaries) v. Commissioner.

United States Tax Court.

Filed June 17, 1986.

Attorney(s) appearing for the Case

Stanley I. Rubenfeld, 53 W Wall St., New York, N.Y., and Alfred Ferrer III, 600 Third Ave., New York, N.Y., for the petitioner. Marwin A. Batt and Arthur Yellin, for the respondent.

Memorandum Findings of Fact and Opinion

NIMS, Judge:

Respondent determined a deficiency of $169,981 in petitioner's Federal income tax for 1969 and issued a statutory notice of deficiency on October 9, 1980. At the same time respondent disallowed a $381,871 claim for refund petitioner had timely filed with respondent on November 26, 1974, for 1969. Petitioner subsequently filed a petition for redetermination of the deficiency and a determination that petitioner...

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