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CONTINENTAL NUT COMPANY v. COMMISSIONER

Docket No. 6813-72.

62 T.C. 771 (1974)

CONTINENTAL NUT COMPANY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 12, 1974.

Attorney(s) appearing for the Case

Jerome N. Field, for the petitioner.

Randall G. Dick, for the respondent.

OPINION

QUEALY, Judge:

Respondent determined a deficiency in the Federal income tax return of the petitioner for the taxable year 1970 in the amount of $76,194.83.

The sole issue for determination is whether petitioner may properly accrue and deduct under section 461 (f)1 certain property taxes which were in dispute during the years involved.

All of the facts have been stipulated, and the case was submitted...

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