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SPITZER COLUMBUS, INC. v. COMMISSIONER

Docket No. 5833-94.

70 T.C.M. 448 (1995)

T.C. Memo. 1995-397

Spitzer Columbus, Inc. v. Commissioner.

United States Tax Court.

Filed August 17, 1995.

Attorney(s) appearing for the Case

Anthony B. Giardini, Lorain, Ohio, for the petitioner. Marc A. Shapiro, for the respondent.

MEMORANDUM OPINION

RAUM, Judge:

The Commissioner determined deficiencies in income tax totaling $129,241.14, $111,344.38, and $108,129.11 for the years 1989, 1990, and 1991, respectively. The issue before us is whether petitioner properly accrued an expense under section 4611 for coupons issued pursuant to a consent judgment entered into in 1989. For reasons appearing in the record, a computation under Rule 155 will be necessary...

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