CONVERGENT TECHNOLOGIES, INC. v. COMMISSIONER

Docket No. 29655-91.

70 T.C.M. 87 (1995)

T.C. Memo. 1995-320

Convergent Technologies, Inc. v. Commissioner.

United States Tax Court.

Filed July 19, 1995.


Attorney(s) appearing for the Case

Andre M. Saltoun, A. Duane Webber, and Diane S. Rohleder, Chicago, Ill., for the petitioner. Steven A. Wilson, Jeffrey L. Heinkel, and Michael F. Steiner, for the respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

TANNENWALD, Judge:

Respondent determined deficiencies in petitioner's 1982 and 1983 Federal income taxes in the amounts of $3,684,885 and $147,646, respectively. After concessions by the parties, we must determine whether warrants issued by petitioner to customers, in 1981, entitle petitioner to a reduction in gross income, or a deduction under section 162,1 and whether petitioner, in an...

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