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PIGGLY WIGGLY SOUTHERN, INC. v. COMMISSIONER

Docket No. 18886-82.

84 T.C. 739 (1985)

PIGGLY WIGGLY SOUTHERN, INC., SOUTHERN GRAPHIC ART, AND GEORGIA SALES COMPANY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 18, 1985.

Attorney(s) appearing for the Case

Charles T. Zink, for the petitioners.

J. Steven Erie, for the respondent.

HAMBLEN, Judge:

Respondent determined the following deficiencies in petitioners' Federal corporate income taxes:

         Fiscal year                   Deficiency

         June 25, 1977 ...............  $82,057.00
         June 24, 1979 ...............    1,271.56

After concessions, the issues for decision are: (1) Whether new equipment purchased by petitioner Piggly Wiggly Southern, Inc. (Piggly Wiggly),

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