GUARDIAN INDUSTRIES CORP. v. COMMISSIONER

Docket No. 27308-87.

97 T.C. 308 (1991)

GUARDIAN INDUSTRIES CORP. AND SUBSIDIARIES, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 11, 1991.


Attorney(s) appearing for the Case

C. David Swenson, A. Duane Webber, and David N. Bowen, for the petitioners.

Robert J. Kastl and James E. Kagy, for the respondent.


WELLS, Judge:

Respondent determined the following deficiencies in petitioners' Federal income tax:

       Year                                        Deficiency

       1983 ...................................... $8,128,580
       1984 ......................................    728,942

After concessions by both parties, the sole issue remaining for decision is whether silver-bearing waste material generated in the course...

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