SERVO CORPORATION OF AMERICA v. COMMISSIONER

Docket No. 4643-93.

68 T.C.M. 1097 (1994)

T.C. Memo. 1994-548

Servo Corporation of America and Servo International Sales Corporation v. Commissioner.

United States Tax Court.

Filed October 31, 1994.


Attorney(s) appearing for the Case

Jeffrey M. Cole, Brian R. Gallagher, and Donald S. Snider, 805 Third Ave., New York, N.Y., for the petitioners. Halvor N. Adams III and Donald Schwartz, for the respondent.


Memorandum Findings of Fact and Opinion

WELLS, Judge.

Respondent determined deficiencies in the Federal income tax of Servo Corp. of America (Servo) in the amount of $58,931 for its taxable year ended October 31, 1984, and $578,235 for its taxable year ended October 31, 1986. After concessions by respondent,1 the issue for decision is whether Servo International Sales Corp. (Servo International), a wholly owned subsidiary of...

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