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PITCHFORD'S, INC. v. COMMISSIONER

Docket No. 1037-72.

34 T.C.M. 384 (1975)

T.C. Memo. 1975-75

Pitchford's, Inc. v. Commissioner.

United States Tax Court.

Filed March 26, 1975.

Attorney(s) appearing for the Case

Garthe Brown, Brian Steenson, Suite 705 Standard Plaza, 1100 S.W. 6th Ave., Portland, Ore. for the petitioner. Gary DeFrang, for the respondent.

Memorandum Findings of Fact and Opinion

HALL, Judge:

Respondent determined deficiencies in petitioner's Federal income tax as follows:

  Year Ended                        Deficiency

  November 30, 1967 ..............  $11,665.99
  November 30, 1968 ..............  $14,992.14

In view of concessions, the only issue remaining is whether respondent was authorized by section 4821 to allocate constructive...

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