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SKAGGS COMPANIES, INC. v. COMMISSIONER

Docket No. 1828-71.

59 T.C. 201 (1972)

SKAGGS COMPANIES, INC., FORMERLY SKAGGS DRUG CENTERS, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed November 7, 1972.

Attorney(s) appearing for the Case

J. Wendell Bayles, for the petitioner.

Joe K. Gordon, for the respondent.

FAY, Judge:

Respondent determined a deficiency in the income tax liability of petitioner for the taxable year ended January 2, 1969, in the amount of $18,640. The issues presented are (1) whether amounts paid to insure the conversion of preferred stock into common stock are nondeductible capital expenditures, or business expenses currently deductible under section 162,1 and (2) if such payments are capital expenditures, are they...

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