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