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TG MISSOURI CORP. v. COMMISSIONER

Docket No. 8333-06.

133 T.C. 278 (2009)

TG MISSOURI CORPORATION F.K.A. TG (U.S.A.) CORPORATION, A MISSOURI CORPORATION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed November 12, 2009.

Attorney(s) appearing for the Case

William E. Elwood, Andrew W. MacLeod, and Peter J. Kulick, for petitioner.*

Meso T. Hammoud, Elizabeth R. Proctor, and Eric R. Skinner, for respondent.

OPINION

MARVEL, Judge:

Respondent determined deficiencies in petitioner's Federal income tax of $3,815,746 and $1,544,033 for 1998 and 1999,1 respectively. After concessions,2 the sole issue for consideration is whether production molds petitioner sold to its customers are assets subject to depreciation for purposes of sections 41 and 174.3 The resolution of that...

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