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[taxpayers'] position is that, under the guise of a duty of
consistency on the part of respondent, they are entitled to 'the
practical equivalent of a double deduction'. See United States
v. Skelly Oil Co., [394 U.S. 678, 684 (1969)]").
Petitioner failed to present any evidence at trial or any
other argument at trial or on brief contesting the correctness of
the adjustments as determined by respondent. Respondent's
adjustments will be sustained.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011