- 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.Page: Previous 1 2 3 4 5
Last modified: May 25, 2011