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C.T.I. INCORPORATED v. COMMISSIONER

Docket No. 21493-91.

67 T.C.M. 2261 (1994)

T.C. Memo. 1994-82

C.T.I. Incorporated v. Commissioner.

United States Tax Court.

Filed February 24, 1994.

Attorney(s) appearing for the Case

John P. Edgar, 1500 Oliver Bldg., Pittsburgh, Pa., Timothy R. Stock, and William C. McClure, 322 Blvd. of the Allies, Pittsburgh, Pa., for the petitioner. Donna P. Leone, for the respondent.

Memorandum Findings of Fact and Opinion

GERBER, Judge:

Respondent determined a $252,640.13 deficiency in petitioner's Federal income tax for its taxable year ended June 30, 1988; a $12,632.01 addition to tax under section 6653(a)(1)(A),1 and 50 percent of the interest due on the deficiency under section 6653(a)(1)(B); and a $64,275.62 addition to tax under section 6661. The issues presented for our consideration are: (1) Whether...

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