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Payless failed to prove that it had a specific written plan
or that it “incurred or committed” more than one-half of the cost
of the “equipped building”. For the reasons stated above, we
find that Payless does not satisfy the requirements of either TRA
section 203(b)(1)(C) or TRA section 204(a)(7) and is not entitled
to the investment credit claimed on its 1986 return.
Decision will be entered
under Rule 155.
11(...continued)
estimated costs).
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Last modified: May 25, 2011