PILGRIM'S PRIDE CORP. v. COMMISSIONER

Docket No. 12089-10.

141 T.C. 533 (2013)

PILGRIM'S PRIDE CORPORATION SUCCESSOR IN INTEREST TO PILGRIM'S PRIDE CORPORATION OF GEORGIA F.K.A. GOLD KIST, INC. SUCCESSOR IN INTEREST TO GOLD KIST INC. AND SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 11, 2013.


Attorney(s) appearing for the Case

Robert H. Albaral and Todd A. Schroeder , for petitioner.

John Wayne Duncan and J. Greg Marble , for respondent.


OPINION

DAWSON, Judge:

Petitioner petitioned the Court pursuant to section 6213(a) and (f)(1)1 for redetermination of a $29,682,682 deficiency in Federal income tax and a $5,936,536 accuracy-related penalty under section 6662(a) that respondent determined against petitioner as successor in interest to Gold Kist Inc. (GK Co-op), a Georgia cooperative marketing association, for its tax year ending June 30, 2004. After a...

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