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FISHER COS. v. COMMISSIONER

Docket No. 16064-83.

84 T.C. 1319 (1985)

FISHER COMPANIES, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 24, 1985.

Attorney(s) appearing for the Case

George T. Cowan, for the petitioner.

Henry Thomas Schafer, for the respondent.

OPINION

SCOTT, Judge:

Respondent determined deficiencies in petitioner's income tax for the calendar years 1977 and 1979 in the respective amounts of $119,234 and $222,856. The issues for decision are: (1) Whether the two-thirds disallowance provision in section 162(g)1 applies to limit the deduction of payments made in 1977 by Fisher Mills, Inc., a subsidiary of petitioner, to...

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