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ARMSTRONG WORLD INDUSTRIES, INC. v. COMMISSIONER

Docket No. 853-89.

62 T.C.M. 148 (1991)

T.C. Memo. 1991-326

Armstrong World Industries, Inc. and Affiliated Companies v. Commissioner.

United States Tax Court.

Filed July 16, 1991.

Attorney(s) appearing for the Case

A. Carl Kaseman III, Stephen R. Mysliwiec, and James G. Rafferty, 1200 Nineteenth St., N.W., Washington, D.C., for the petitioner. Eugene J. Wien and Judy Jacobs Miller, for the respondent.

Memorandum Findings of Fact and Opinion

COHEN, Judge:

Respondent determined a deficiency of $5,032,135 in petitioner's Federal income tax for 1981.

The issues for decision are (1) whether petitioner's transactions with Conrail complied with the requirements of section 168(f)(8) with respect to safe harbor leasing, thus entitling petitioner to certain investment tax credits and depreciation deductions...

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