AFFILIATED FOODS, INC. v. COMMISSIONER

AFFILIATED FOODS, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

AFFILIATED FOODS, INC. v. COMMISSIONER

Docket No. 25703-93

United States Tax Court

T.C. Memo 1996-505; 1996 Tax Ct. Memo LEXIS 521; 72 T.C.M. (CCH) 1226;

November 7, 1996, Filed

Decision will be entered under Rule 155.

William A. Hoy, for petitioner.

George E. Gasper, for respondent.

PARR

PARR

MEMORANDUM FINDINGS OF FACT AND OPINION

PARR, Judge: Respondent determined deficiencies in petitioner's Federal income tax for taxable years 1989 and 1990 of $ 171,985.68 and $ 183,196.30, respectively. The issues for decision are:…