- 5 -
Primo Pants Co. v. Commissioner, supra; Hitachi Sales Corp. of
Am. v. Commissioner, supra.
Accordingly, we hold that a section 481 adjustment is a
proper matter for Rule 155 consideration.
To reflect the foregoing,
An appropriate order will
be issued.
4(...continued)
describe the basis on which the Commissioner relied to support
the Commissioner's deficiency determination. See also sec. 7522.
In the case at bar, however, sec. 481 is more than implicit in
the notice; it is patent.
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Last modified: May 25, 2011