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THOMAS P. BYRNES, INC. v. COMMISSIONER

Docket No. 8679-78.

73 T.C. 416 (1979)

THOMAS P. BYRNES, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 4, 1979.

Attorney(s) appearing for the Case

Francis X. McCormick, for the petitioner.

Bernard Wishnia, for the respondent.

NIMS, Judge:

Respondent determined deficiencies of $20,460, $24,566, and $31,830 for the respective taxable years ending March 31, 1973, March 31, 1975, and March 31, 1976. The issue for our decision is whether amounts petitioner received for the performance of contractual obligations constituted personal holding company income within the meaning of section 543(a)(7),1 thereby subjecting petitioner to personal holding company tax...

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