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SUNDSTRAND CORP. v. COMMISSIONER

Docket No. 26230-83.

96 T.C. 226 (1991)

SUNDSTRAND CORPORATION AND SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 19, 1991.

Attorney(s) appearing for the Case

John C. Klotsche, Michael Waris, Jr., James M. O'Brien, Mark A. Oates, Bertrand M. Harding, Jr., Robert H. Albaral, and Neil D. Traubenberg, for the petitioner.

Reid M. Huey, Joel D. Arnold, Elaine H. Geer, and David L. Zoss, for the respondent.

HAMBLEN, Judge:

Respondent determined deficiencies of $1,569,156 and $5,931,159 in petitioner's1 Federal income tax for taxable years ending December 31, 1977, and December 31, 1978, respectively (hereinafter sometimes referred to as the years in issue).

STATEMENT OF ISSUES

The issues involved in this case are as follows:

1. Whether respondent's allocations of gross...

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