Adolph Coors Company v. Commissioner of Internal Revenue

HILL, Circuit Judge.

This is an appeal by Adolph Coors Company (taxpayer) from a United States Tax Court decision sustaining the Commissioner of Internal Revenue’s determination of federal income tax deficiencies for the years 1965 and 1966 in the amounts of $3,838,154.33 and $1,268,-786.83, respectively.

The relevant facts may be summarized as follows. Taxpayer is a Colorado corporation engaged in the production and sale of beer. It uses its own equipment and employees in the construction of improvements and additions to its capital facilities. Taxpayer employed 398 construction personnel (37%…