T.C. Memo. 1997-495
UNITED STATES TAX COURT
CHOATE CONSTRUCTION CO., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 20781-95. Filed November 4, 1997.
Matthew J. Howard, for petitioner.
Larry D. Anderson, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge: Respondent determined a $212,580 deficiency
in petitioner's income tax for 1992.
William Millard Choate (Choate) is petitioner's founder and
chief executive officer (CEO). After concessions, the sole issue
for decision is whether petitioner may deduct $1,010,000 in
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