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BENTLY LABORATORIES, INC. v. COMMISSIONER

Docket Nos. 7755-76, 1232-78.

77 T.C. 152 (1981)

BENTLY LABORATORIES, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. BENTLY LABORATORIES, INC., AND SENSOREX, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed July 30, 1981.

Attorney(s) appearing for the Case

C. Craig Carlson and Douglas F. Higham, for the petitioners.

John O. Kent, for the respondent.

OPINION

RAUM, Judge:

The Commissioner determined deficiencies of $453,968 and $438,995 in petitioners' 1972 and 1973 income taxes, respectively. Petitioner Bentley Laboratories, Inc. (Bentley Labs or Labs), owns all of the stock of Bentley International Ltd., a domestic international sales corporation (DISC or International). Bentley Labs is an accrual basis taxpayer with a fiscal year ending November 30, and the DISC is an accrual basis taxpayer...

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