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EMI CORPORATION v. COMMISSIONER

Docket No. 1163-81.

50 T.C.M. 569 (1985)

T.C. Memo. 1985-386

EMI Corporation, an Illinois Corporation v. Commissioner.

United States Tax Court.

Filed July 31, 1985.

Attorney(s) appearing for the Case

Leslie R. Bishop, Robert A. Hall, and Leonard S. DeFranco, for the petitioner. Thomas E. Ritter, for the respondent.

Memorandum Findings of Fact and Opinion

PARKER, Judge:

Respondent determined deficiencies in petitioner's corporate income tax of $41,600.72, $49,041.66, and $104,576.55 for its respective fiscal years ending August 31, 1975, August 31, 1976, and August 31, 1977. The sole issue for decision is whether, under section 532(a),1 petitioner was availed of for the purpose of avoiding...

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