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SNOW MANUFACTURING CO. v. COMMISSIONER

Docket No. 25950-82.

86 T.C. 260 (1986)

SNOW MANUFACTURING COMPANY, A DISSOLVED CALIFORNIA CORPORATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 4, 1986.

Attorney(s) appearing for the Case

David M. Rosenberger, Joseph Enzo Zerbini, Robert K. Johnson, Allen M. Katz, and Ellen P. Aprill, for the petitioner.

Karl D. Zufelt and Erin Collins, for the respondent.

GERBER Judge:

Respondent determined deficiencies in petitioner's income tax for petitioner's taxable years ended June 30, 1979, and June 30, 1980, in the respective amounts of $109,816 and $70,968. After concessions, the issue before us is whether petitioner is liable for the accumulated earnings tax imposed by section 531.1

FINDINGS OF FACT

Some of the facts have been...

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