SIERRACIN CORP. v. COMMISSIONER

Docket No. 28569-83.

90 T.C. 341 (1988)

SIERRACIN CORPORATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 9, 1988.


Attorney(s) appearing for the Case

McGee Grigsby, Linda F. Powers, and Joseph A. DeFrancis, for the petitioner.

Charles O. Cobb and Ross W. Paulson, for the respondent.


COHEN, Judge:

Respondent determined deficiencies in petitioner's corporate income tax as follows:

Year                                 Deficiency

1976 ..............................   $519,726
1977 ..............................    359,422
1979 ..............................    421,040
1980 ..............................  1,361,312

After concessions, the issues for decision are (1) whether, during the years in issue...

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