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ROUNTREE COTTON CO. v. COMMISSIONER

Docket No. 24014-97.

113 T.C. 422 (1999)

ROUNTREE COTTON CO., INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 16, 1999.

Attorney(s) appearing for the Case

Towner Leeper, for petitioner.

Gerald L. Brantley, for respondent.

OPINION

GERBER, Judge:

Respondent determined income tax deficiencies in petitioner's taxable years ended August 31, 1994 and 1995, in the amounts of $19,094 and $16,944, respectively. The deficiencies are attributable to respondent's determination that petitioner made "below-market loans" within the meaning of section 7872.1 More particularly, we consider a question of first impression of whether the provisions of section...

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