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ELBO COALS, INC. v. COMMISSIONER

Docket No. 1136-84.

52 T.C.M. 1275 (1987)

T.C. Memo. 1987-2

Elbo Coals, Inc. v. Commissioner.

United States Tax Court.

Filed January 5, 1987.

Attorney(s) appearing for the Case

D. Randall Gibson, 2500 Brown & Williamson Tower, Louisville, Ky., for the petitioner. Aubrey C. Brown, for the respondent.

Memorandum Findings of Fact and Opinion

SHIELDS, Judge:

Respondent determined a deficiency in petitioner's income tax of $480,000 for the fiscal year ended June 30, 1979. The issues for decision are: (1) whether petitioner is entitled to use section 13411 to compute its tax liability for 1979; and (2) if so, whether section 1341 applies to all or just a portion of a payment in the amount of $1,000,000 made by petitioner in 1979...

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