Karns Prime & Fancy Food, Ltd. - Page 1

                                                                                     









                                 T.C. Memo. 2005-233                                  


                               UNITED STATES TAX COURT                                


                    KARNS PRIME & FANCY FOOD, LTD., Petitioner v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 906-04.               Filed October 5, 2005.                


               John D. Sheridan and Steven J. Schiffman, for petitioner.              
               Gerald A. Thorpe, for respondent.                                      


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               CHIECHI, Judge:  Respondent determined a deficiency of                 
          $486,355 in petitioner’s Federal income tax (tax) for the taxable           
          year ended January 30, 2000 (year at issue).                                
               The only issue for decision is whether the $1.5 million                
          ($1.5 million at issue) that petitioner received from its princi-           
          pal supplier during the year at issue constitutes a loan that is            





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