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CLARK EQUIPMENT COMPANY v. COMMISSIONER

Docket No. 21912-85.

55 T.C.M. 389 (1988)

T.C. Memo. 1988-111

Clark Equipment Company and Consolidated Subsidiaries v. Commissioner.

United States Tax Court.

Filed March 14, 1988.

Attorney(s) appearing for the Case

Robert D. Heyde, Sonia M. Pawluc, and Cora Nell Haggard, 3200 Miami Center, Miami, Fla., for the petitioners. William E. Bogner and Sheldon M. Kay, for the respondent.

Memorandum Findings of Fact and Opinion

COHEN, Judge:

Respondent determined the following deficiencies in petitioner's corporate income tax:

  Year                           Deficiency

  1974 ....................... $    93,445.00
  1975 .......................   2,554,661.00
  1976 .......................   2,395,109.00
  1977 .......................  10,454,606.35

After concessions, the primary issue for decision...

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