T.C. Memo. 2001-175
UNITED STATES TAX COURT
WESTPAC PACIFIC FOODS,
SAVE MART, TAX MATTERS PARTNER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12400-99. Filed July 16, 2001.
Andrew A. Bassak and Alvin T. Levitt, for petitioner.
Andrew R. Moore and Lloyd T. Silberzweig, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge: By way of separate notices of final
partnership administrative adjustment, respondent determined that
Westpac Pacific Foods (Westpac) failed to report $5,572,538 and
$4,922,945 of gross income for taxable years 1990 and 1991,
respectively. The sole matter for decision is whether certain
upfront payments that Westpac received in consideration of
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