- 2 -
Held: Because Congress did not intend to
prescribe or preclude rules for the treatment of costs
under the sec. 458, I.R.C., election, the regulation
does not conflict with this section and is valid.
Daniel M. Davidson and John Wester, for petitioners.
John A. Guarnieri and Douglas A. Fendrick, for respondent.
OPINION
LARO, Judge: These cases were consolidated for trial,
briefing, and opinion, and submitted to the Court without trial
pursuant to Rule 122(a).1 Hachette USA, Inc. (Hachette USA), and
its subsidiary Curtis Circulation Co. (Curtis) petitioned the
Court for redetermination of the following Federal income tax
deficiencies determined by respondent:
Docket No. 11693-94:
Taxable Year Deficiency
1987 $665,225
Docket No. 11694-94:
Taxable Year Deficiency
1987 $139,502
Tax Year Ended Deficiency
Nov. 30, 1988 $2,535,928
1 All Rule references are to the Tax Court Rules of Practice
and Procedure and, unless otherwise indicated, section references
are to the Internal Revenue Code for the years at issue.
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Last modified: May 25, 2011