T.C. Memo. 1996-489
UNITED STATES TAX COURT
THE CLEVELAND TRENCHER COMPANY, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 14558-93. Filed October 30, 1996.
Metin Aydin (an officer), for petitioner.
Marc A. Shapiro, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
BEGHE, Judge: Respondent determined a deficiency of
$56,609 in petitioner's income tax for the taxable year ended
September 30, 1989. After concessions, the sole issue for
decision is whether petitioner is entitled to a deduction for
$168,099 of commission expense that respondent disallowed.
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