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MEDIA SPACE, INC. v. COMMISSIONER

Docket No. 25696-08.

135 T.C. 424 (2010)

MEDIA SPACE, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed October 18, 2010.

Attorney(s) appearing for the Case

Dustin F. Hecker and Steven A. Meyer , for petitioner.

William T. Derick , for respondent.

OPINION

GOEKE, Judge:

Respondent determined deficiencies in petitioner's income tax for the taxable years 2004 and 2005. The issue for decision is whether payments petitioner made to shareholders to delay redemption of their preferred shares are deductible under section 162 or 163.1 For the reasons stated herein, we find that the payments are deductible in part under section 162...

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