Docket No. 639-95.

72 T.C.M. 830 (1996)

T.C. Memo. 1996-450

Theodore Souris, P.C., a Dissolved Corporation, and Theodore Souris, as Successor in Interest of Theodore Souris, P.C. v. Commissioner.

United States Tax Court.

Filed October 2, 1996.

Attorney(s) appearing for the Case

Patricia D. White, Detroit, Mich., for the petitioners. Meso T. Hammoud, for the respondent.


RAUM, Judge:

The Commissioner determined a $48,905 deficiency in petitioner corporation's 1988 income tax together with a $9,781 section 6661(a)1 addition to tax for that year. The principal issue presented is whether the petitioner corporation's $171,476 "employer reversion", section 4980(c)(2)(A), which is concededly includable in its gross income, may be offset by a section 162(a)(1) deduction in the same...

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