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PARKER-HANNIFIN CORP. v. C.I.R.

No. 96-2580.

139 F.3d 1090 (1998)

PARKER-HANNIFIN CORPORATION, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided March 23, 1998.

Attorney(s) appearing for the Case

William R. Stewart (argued and briefed), Thompson, Hine & Flory, Cleveland, OH, for Petitioner-Appellant.

Gary R. Allen, Acting Chief, Kenneth L. Greene (briefed), Annette Wietecha (argued and briefed), U.S. Department of Justice, Appellate Section Tax Division, Washington, DC, for Respondent-Appellee.

Before: NELSON, SUHRHEINRICH, and GILMAN, Circuit Judges.

OPINION

SUHRHEINRICH, Circuit Judge.

Parker-Hannifin Corporation (Parker) appeals from the judgment of the United States Tax Court disallowing a substantial portion of the income tax deduction it claimed for its $42 million contribution to a welfare benefit fund on June 30, 1987. We AFFIRM IN PART AND REVERSE IN PART.

I.

The facts are set forth in greater detail in the Tax Court's opinion at T.C. Memo.1996-337, 1996 WL 412009...

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