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CSI HYDROSTATIC TESTERS, INC. v. COMMISSIONER

Docket No. 26350-91.

103 T.C. 398 (1994)

CSI HYDROSTATIC TESTERS, INC., AND SUBSIDIARIES, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 30, 1994.

Attorney(s) appearing for the Case

Steven I. Klein and Susan Whittington Leidner, for petitioners.

Linda K. West, Louis John Zeller, Jr., Alfred C. Bishop, Jr., and Richard L. Osborne, for respondent.

OPINION

WELLS, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for their taxable year ended May 31, 1987, in the amount of $1,513,943.1 The issues for decision are: (1) Whether cancellation of indebtedness (COD) income that was excluded from the taxable income of a subsidiary corporation, under section 108(a),2 should be

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