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CARLAND, INC. v. C.I.R.

No. 89-2148.

909 F.2d 1101 (1990)

CARLAND, INC., Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided July 12, 1990.

Rehearing Denied August 21, 1990.

Attorney(s) appearing for the Case

J. Glenn Hahn, Kansas City, Mo., for appellant.

Robert W. Metzler, Washington, D.C., for appellee.

Before LAY, Chief Judge, BEAM, Circuit Judge, and WOODS, District Judge.

LAY, Chief Judge.

Carland, Inc. (Carland) appeals the Tax Court's decision upholding income tax deficiencies assessed by the Commissioner of Internal Revenue (Commissioner) for the years 1970-1975. The Tax Court sustained deficiencies in the following amounts: 1970 — $586,844; 1971 — $480,858; 1972 — $212,449; 1973 — $37,128; 1974 — $36,420; 1975 — $11,227. We affirm in part and reverse in part.

I. BACKGROUND

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