Docket No. 22121-93.

72 T.C.M. 191 (1996)

T.C. Memo. 1996-337

Parker-Hannifin Corporation v. Commissioner.

United States Tax Court.

Filed July 24, 1996.

Attorney(s) appearing for the Case

William R. Stewart, Cleveland, Ohio, Kent L. Mann, Karen E. Rubin, Stephen F. Gladstone, and Dena M. Kobasic, for the petitioner. Elsie Hall, Randall P. Andreozzi, and Katherine L. Wambsgans, for the respondent.


COHEN, Chief Judge:

Respondent determined a deficiency of $15,007,108 in petitioner's 1987 Federal income tax. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. The use of the term "reserve" in this opinion is for convenience and is not conclusive as to characterization for...

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