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AMFAC, INC. v. COMMISSIONER

Docket No. 7236-75.

70 T.C. 305 (1978)

AMFAC, INC., ET AL., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 23, 1978.

Attorney(s) appearing for the Case

Richard L. Griffith, for the petitioner.

Vernon R. Balmes, for the respondent.

STERRETT, Judge:

Respondent, on May 16, 1975, issued a statutory notice in which he determined a deficiency of $170,315 in petitioner's corporate income tax. The issue presented for our determination is whether petitioner may deduct under section 175(a), I.R.C. 1954, expenditures, otherwise characterized as capital in nature, incurred in 1969 to improve three fields.

FINDINGS OF FACT

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