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BWIT FIFTY-FIFTY STREET, INC. v. COMMISSIONER

Docket No. 43158-85.

54 T.C.M. 858 (1987)

T.C. Memo. 1987-516

BWIT Fifty-Fifth Street, Inc. d/b/a The Lexington Group, Inc. v. Commissioner.

United States Tax Court.

Filed October 1, 1987.

Attorney(s) appearing for the Case

Richard E. Thigpen, Jr. and Richard M. Thigpen, 300 NCNB Plaza, Charlotte, N.C., for the petitioner. Frank D. Armstrong, Jr., for the respondent.

Memorandum Opinion

KÖRNER, Judge:

In his notice of deficiency respondent determined deficiencies in petitioner's Federal income tax as follows:

Year Ended
  July 31                     Deficiency

   1980 ...................    $  9,643
   1981 ...................     119,219

After concessions, the sole issue for decision is whether petitioner is entitled to deduct compensation expense accrued but not...

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