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FRITZSCHE DODGE & OLCOTT, INC. v. COMMISSIONER

Docket No. 1494-79.

45 T.C.M. 607 (1983)

T.C. Memo. 1983-56

Fritzsche Dodge & Olcott, Inc. v. Commissioner.

United States Tax Court.

Filed January 31, 1983.

Attorney(s) appearing for the Case

Paul D. Seghers and Joseph M. Persinger, for the petitioner. David M. Brandes and Michael Kevin Phalin, for the respondent.

Memorandum Opinion

HAMBLEN, Judge:

Respondent determined deficiencies of $163,252.64 and $63,157.44, respectively, in petitioner's 1974 and 1975 Federal income tax. The sole issue for decision is whether petitioner's wholly-owned subsidiary, Fritzsche Dodge & Olcott International, Inc., qualified as a Domestic International Sales Corporation (hereinafter DISC) under section 992(a)1<...

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