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ALLIED INDUSTRIAL CARTAGE CO. v. COMMISSIONER

Docket No. 7918-77.

72 T.C. 515 (1979)

ALLIED INDUSTRIAL CARTAGE COMPANY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 20, 1979.

Attorney(s) appearing for the Case

Robert I. Alpern, for the petitioner.

Thomas E. Ritter, for the respondent.

STERRETT, Judge:

Respondent, on April 29, 1977, issued a statutory notice in which he determined a deficiency in petitioner's Federal corporate income tax return for its taxable year ended February 28, 1974, in the amount of $8,047.90. The narrow issue presented to the Court is whether the sole shareholder of a lessee corporation will be treated as "an individual entitled to the use of property" under section 543(a)(6), I.R.C. 1954.

FINDINGS OF FACT...

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