ASAT, INC. v. COMMISSIONER

Docket No. 3173-95.

108 T.C. 147 (1997)

ASAT, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 31, 1997.


Attorney(s) appearing for the Case

James E. Merritt, Linda A. Arnsbarger, and Thomas H. Steele, for petitioner.1

Mary E. Wynne, Michael F. Steiner, and Grace L. Perez-Navarro, for respondent.


VASQUEZ, Judge:

Respondent determined a deficiency in petitioner's Federal income tax in the amount of $407,592 and an accuracy-related penalty under section 6662(a)2 of $81,518 for its taxable year ending April 30, 1991. Although respondent gave alternative grounds for each adjustment in the notice of deficiency, her first ground in regard to petitioner's cost of goods sold and net operating loss was section 6038A(e)(3), which...

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