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CARNATION CO. v. COMMISSIONER

Docket No. 5793-76.

71 T.C. 400 (1978)

CARNATION COMPANY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 26, 1978.

Attorney(s) appearing for the Case

J. Patrick Whaley and David W. Richmond, for the petitioner.

Alan S. Beinhorn, for the respondent.

OPINION

GOFFE, Judge:

The Commissioner determined a deficiency in the Federal income tax of petitioner for the taxable year 1972 in the amount of $823,632. This matter is before the Court on the parties' motions for summary judgment which were filed pursuant to Rule 121, Tax Court Rules of Practice and Procedure. Due to concessions, three issues remain for our decision:

(1) Whether petitioner is entitled...

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