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BROWN GROUP, INC. & SUBS. v. COMMISSIONER

Docket No. 104-92.

104 T.C. 105 (1995)

BROWN GROUP, INC. AND SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 25, 1995.

Attorney(s) appearing for the Case

Harold G. Blatt, Juan D. Keller, and Philip B. Wright, for petitioner.

James A. Kutten and Richard A. Witkowski, for respondent.

HALPERN, Judge:

Petitioner is the common parent corporation of an affiliated group of corporations making a consolidated return of income (the affiliated group). Respondent determined a deficiency of $388,992.85 in the income tax liability of the affiliated group for its taxable year ended November 1, 1986.1

The only issue in dispute is whether Brown Cayman, Ltd.'s (Brown Cayman's) share of partnership income from Brinco...

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