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EDISON BROTHERS STORES, INC. v. COMMISSIONER

Docket No. 26644-93.

69 T.C.M. 2897 (1995)

T.C. Memo. 1995-262

Edison Brothers Stores, Inc. and Subsidiaries v. Commissioner.

United States Tax Court.

Filed June 14, 1995.

Attorney(s) appearing for the Case

John P. Barrie and Harold G. Blatt, St. Louis, Mo., for the petitioner. Donald L. Wells, for the respondent.

Memorandum Opinion

LARO, Judge:

This case was submitted to the Court fully stipulated.1 Edison Brothers Stores, Inc., & Subsidiaries petitioned the Court to redetermine respondent's determination of a $4,910,206 deficiency in its Federal income tax for its taxable year ended December 28, 1985. We must decide whether petitioner may deduct under section 461(f) moneys transferred to an irrevocable trust; the trust's sole purpose...

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