FIDELITY ASSOCIATES, INC. v. COMMISSIONER

Docket No. 19277-88.

63 T.C.M. 2327 (1992)

T.C. Memo. 1992-142

Fidelity Associates, Inc., James P. Cherry, Sr., Tax Matters Person v. Commissioner.

United States Tax Court.

Filed March 10, 1992.


Attorney(s) appearing for the Case

David M. Furr and Joseph B. Alala, Jr., 301 S. York St., Gastonia, N.C., for the petitioner. Ross A. Rowley and Paul G. Topolka, for respondent.


Memorandum Findings of Fact and Opinion

GERBER, Judge:

This is a proceeding pursuant to sections 6226-62311 for a readjustment of subchapter S items of Fidelity Associates, Inc.,2 an S corporation, for the taxable year ending December 31, 1983.

The issues for decision are: (1) Whether petitioner is entitled, under section 446(a), to deduct paid and accrued commission expenses concerning sales...

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