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and UCFSC in order for petitioner to claim additional
FSC commission expenses for the years in dispute.
2. Held, further, sec. 1.925(a)-1T(e)(4),
Temporary Income Tax Regs., supra, is valid.
Thomas M. Haderlein, James M. O'Brien, Jeffrey M. O'Donnell,
Tamara L. Frantzan, and Jerry L. Robinson, for petitioner.
Steven R. Winningham and Joseph F. Long, for respondent.
OPINION
NIMS, Judge: This matter is before the Court on
petitioner's motion and respondent's cross-motion for partial
summary judgment filed pursuant to Rule 121.
Unless otherwise indicated, all section references are to
sections of the Internal Revenue Code in effect for the years at
issue. All Rule references are to the Tax Court Rules of
Practice and Procedure.
Respondent determined deficiencies in the Federal income
taxes of petitioner for its taxable years ending December 31,
1987, 1988, and 1989 as follows:
Year Deficiency
1987 $387,887
1988 24,156,481
1989 32,903,323
The issues for decision are: (1) Whether petitioner can
claim additional foreign sales corporation (FSC) commission
expenses pursuant to section 1.925(a)-1T(e)(4), Temporary Income
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