- 2 - the statutory notice, and petitioner raised a new issue in its petition. Seven issues were settled by the parties before trial, and one (the research credit issue) has been deferred for later trial or other disposition. Two issues were settled after trial. The issue addressed in this opinion is whether petitioner may depreciate, upon application of the rule of Cohan v. Commissioner, 39 F.2d 540 (2d Cir. 1930), approximately $2 million in expenditures for which complete and correct records were not maintained. 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 Petitioner is a Delaware corporation with its principal offices located in Springdale, Arkansas. During the years in issue, petitioner was the world’s largest fully integrated producer, processor, and marketer of poultry-based food products. By the end of 1991, Culinary Foods, Inc. (Culinary), based in Chicago, Illinois, was a well-established manufacturer of frozen food products for institutional buyers, as well as other food products for the airline industry. At that time, Culinary operated through two integrated manufacturing facilities located on the north side of Chicago.Page: Previous 1 2 3 4 5 6 7 8 9 10 NextLast modified: November 10, 2007