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EPCO, INC. v. C.I.R.

No. 96-1204.

104 F.3d 170 (1997)

EPCO, INC. and Subsidiaries, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Eighth Circuit.

Decided January 6, 1997.

Attorney(s) appearing for the Case

Juan D. Keller, argued, St. Louis (Philip B. Wright, on the brief), for petitioner.

John A. Nolet, Department of Justice, argued, Washington, DC (Gary R. Allen, Jonathan S. Cohen, on the brief), for respondent.

Before RICHARD S. ARNOLD, Chief Judge, MAGILL, Circuit Judge, and SACHS, District Judge.

RICHARD S. ARNOLD, Chief Judge.

Imperial Utility Corporation, a wholly owned subsidiary of EPCO, Inc., together with Brooks McArthy, a developer, paid for the construction of a sewer pipeline to service a tract of land owned by McArthy on which he planned to develop a mobile home park. McArthy contributed $200,000 to the construction of the sewer line, which is owned by Imperial. The Commissioner of Internal Revenue found a deficiency in EPCO's 1989 federal income...

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