Advo, Inc. & Subsidiaries v. Commissioner

141 T.C. No. 9

UNITED STATES TAX COURT ADVO, INC. & SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 17247-10. Filed October 24, 2013. R disallowed a deduction P claimed under I.R.C. sec. 199 of $1,515,992 for the 2006 tax year and $151,047 for the short 2007 tax year. R determined that P was not considered to have manufactured, produced, grown, or extracted qualifying production property under I.R.C. sec. 199 with respect to P’s direct advertising mailings. Held: P did not have the benefits and burdens of ownership of the direct advertising materials and is…