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HOME JUICE COMPANY, INC. v. COMMISSIONER

Docket No. 701-76.

36 T.C.M. 1566 (1977)

T.C. Memo. 1977-386

Home Juice Company, Inc. v. Commissioner.

United States Tax Court.

Filed November 3, 1977.

Attorney(s) appearing for the Case

Joel L. Miller and William E. Rattner, 208 S. La Salle, Chicago, Ill., for the petitioner. James F. Kidd, for the respondent.

Memorandum Findings of Fact and Opinion

FEATHERSTON, Judge:

Respondent determined deficiencies in the amounts of $52,391.23 and $27,669.35 in petitioner's Federal income taxes for 1971 and 1972, respectively. The issues in controversy are:

1. Whether petitioner recognized income under section 61(a)1 in the form of purchase rebates of $109,148.44 and $59,260.30 paid to its sole...

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