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GIBSON & ASSOCIATES, INC. v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 5863-08.

136 T.C. 195 (2011)

GIBSON & ASSOCIATES, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 24, 2011.

Attorney(s) appearing for the Case

Charles D. Lieser , for petitioner.

George E. Gasper , for respondent.

PARIS, Judge:

Petitioner petitioned the Court to redetermine respondent's determination of a $21,568 deficiency in its Federal income tax for its taxable year ended June 30, 2006 (subject year). The deficiency results from respondent's determination that petitioner may not deduct $63,435 under section 199(a).1 Respondent disallowed that deduction after determining that petitioner had no "domestic production gross receipts" (DPGR...

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