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FRIENDSHIP DAIRIES, INC. v. COMMISSIONER

Docket No. 31368-85.

90 T.C. 1054 (1988)

FRIENDSHIP DAIRIES, INC. AND SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 23, 1988.

Attorney(s) appearing for the Case

Robert H. Aland, Gregg D. Lemein, Frederick P. Wick, Jr., and Frederick E. Henry III, for the petitioner.

Lawrence C. Letkewicz and Joel D. Arnold, for the respondent.

COHEN, Judge:

Respondent determined a deficiency of $298,672 in petitioner's income tax for the taxable year ended September 27, 1980. Respondent also determined that such deficiency is subject to an addition to tax pursuant to section 6621(c).1

The issues for decision are as follows:

(1) Whether petitioner's purchase of an IBM. Model 3033N8 computer and related equipment...

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