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CIRCLE K CORPORATION AND CONSOLIDATED SUBSIDIARIES v. COMMISSIONER

Docket No. 3542-80.

43 T.C.M. 1524 (1982)

T.C. Memo. 1982-298

Circle K Corporation and Consolidated Subsidiaries v. Commissioner.

United States Tax Court.

Filed May 26, 1982.

Attorney(s) appearing for the Case

A. Jerry Busby, Luhrs Tower Building, 11 West Jefferson Street, Phoenix, Ariz. 85003, for the petitioners. Michael K. Phalin, for the respondent.

Memorandum Findings of Fact and Opinion

WILES, Judge:

Respondent determined a deficiency of $172,527 in petitioners' Federal income tax for the taxable year ended April 30, 1976, and imposed an addition to tax of $8,626 under section 6653(a).1 The issues for decision are:

1. Whether certain property qualifies as section 38 property so as to entitle petitioners to investment...

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