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BROWN-FORMAN CORP. v. COMMISSIONER

Docket No. 27494-87.

94 T.C. 919 (1990)

BROWN-FORMAN CORPORATION (A DELAWARE CORPORATION), SUCCESSOR BY MERGER TO BROWN-FORMAN CORPORATION (A TENNESSEE CORPORATION), SUCCESSOR IN INTEREST TO SOUTHERN COMFORT CORPORATION (A DELAWARE CORPORATION), PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 25, 1990.

Attorney(s) appearing for the Case

Walter D. Haynes, for the petitioner.

Aubrey C. Brown, for the respondent.

WELLS, Judge:

Respondent determined deficiencies in Federal income tax as follows:

    TYE                                     Amount
Apr. 30, 1981 ............................  $1,668,237
Apr. 30, 1983 ............................     319,381

After concessions by petitioner, the issues for consideration herein are as follows: (1) Whether "gross receipts" from domestic sales, for purposes of the "overall profit percentage...

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