T.C. Memo. 1998-342 UNITED STATES TAX COURT KENCO RESTAURANTS, INC., ET AL.,1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 15949-95, 15950-95 Filed September 24, 1998. 15951-95, 15952-95. Pursuant to sec. 482, I.R.C., R reallocated among a group of commonly owned corporations certain management service fees charged by one member of the group to the other members. Held: Ps have failed to prove that R abused his discretion by making an arbitrary, capricious, or unreasonable reallocation. Held, further, Ps were negligent in making their initial allocation. John D. Steffan, for petitioners. Diane D. Helfgott, for respondent. 1 Cases of the following petitioners are consolidated herewith: K-K Restaurants, Inc., docket No. 15950-95; Bryan Realty, Inc., docket No. 15951-95; Tiffin Avenue Realty Co., Inc., docket No. 15952-95.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011