CITY INVESTING COMPANY v. COMMISSIONER

Docket No. 17739-82.

52 T.C.M. 1422 (1987)

T.C. Memo. 1987-36

City Investing Company v. Commissioner.

United States Tax Court.

Filed January 15, 1987.


Attorney(s) appearing for the Case

John S. Breckinridge, Jr. and F. Brook Voght, for the petitioner. David N. Brodsky and Robert J. Foley, for the respondent.


Memorandum Findings of Fact and Opinion

GERBER, Judge:

Respondent determined deficiencies in petitioner's Federal income tax for taxable years 1968, 1969 and 1970 as follows:

  Year                        Deficiency

  1968 .....................   $   208,673
  1969 .....................    19,789,652
  1970 .....................     1,406,012

After concessions, the issue presented is whether unpaid commissions to...

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