NESTLE HOLDINGS, INC. v. COMMISSIONER

Docket No. 24080-88.

94 T.C. 803 (1990)

NESTLÉ HOLDINGS, INC. AND CONSOLIDATED SUBSIDIARIES, AS SUCCESSOR IN INTEREST TO NESTLE ENTERPRISES, INC. AND CONSOLIDATED SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 6, 1990.


Attorney(s) appearing for the Case

Joel V. Williamson, William A. Schmalzl, Thomas C. Durham, Alexander Spitzer, Gary P. Kirschenbaum, Joseph R. Goeke, and Gregory L. Barton, for the petitioner.

Theodore J. Kletnick, Sharon Katz-Pearlman, and Jeannette D. Schmelzle, for the respondent.


OPINION

GOFFE, Judge:

The case is presently before us on cross-motions for partial summary judgment under Rule 121(b).1 There is no genuine issue as to any material fact with respect to the question presented.

The Commissioner determined the following deficiencies in, and additions to, petitioner's Federal income taxes:

                                  Addition to tax
     TYE      ...

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