Prudential Overall Supply - Page 2




                                        - 2 -                                         
                          1996                719,096                                 
          Docket No. 8875-00                                                          
                          Year             Deficiency                                 
                          1997               $665,458                                 
                          1998              1,036,011                                 
          After concessions by the parties, the issue remaining for                   
          decision is whether it was an abuse of discretion, under section            
          446(b), to require petitioner to capitalize and depreciate the              
          cost of the garments and dust control items used in petitioner’s            
          industrial laundry business.                                                
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the years in issue, and             
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated in our findings by this reference.  Unless           
          otherwise indicated, the facts and events contained herein                  
          occurred during the years in issue.                                         
               Petitioner is a California corporation with its principal              
          place of business in Irvine, California.  Petitioner is in the              
          industrial laundry business, which provides, launders, repairs              
          and maintains, and services garments worn by the employees of               
          petitioner’s customers.  Petitioner offers industrial garments              
          and dust control items at about 20 locations in four States and             





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