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HERSHEY FOODS CORP. v. COMMISSIONER

Docket No. 9121-80T.

76 T.C. 312 (1981)

HERSHEY FOODS CORPORATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 18, 1981.

Attorney(s) appearing for the Case

Jerome B. Libin and Leonard B. Terr, for the petitioner.

L. Michael Wachtel, for the respondent.

OPINION

FAY, Judge:

Respondent determined petitioner is not entitled to a favorable ruling under section 3671 unless petitioner agrees to include certain amounts in income. Having exhausted its administrative remedies as required by section 7477(b)(2), petitioner has timely invoked the jurisdiction of this Court for a declaratory judgment pursuant to section 7477(a). The issue is whether respondent's determination is reasonable...

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