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AMERICAN TELEPHONE AND TELEGRAPH CO. v. COMMISSIONER

Docket No. 40990-85.

55 T.C.M. 16 (1988)

T.C. Memo. 1988-35

American Telephone and Telegraph Company and Consolidated Subsidiaries v. Commissioner.

United States Tax Court.

Filed February 3, 1988.

Attorney(s) appearing for the Case

Jerome B. Libin, 1275 Pennsylvania Ave., N.W., Washington, D.C., Bradley M. Seltzer, Stephen F. Gertzman, Allan J. Stein, Susan Flax Posner, Martin J. Eisen and Lawrence H. Cohen, for the petitioners. David N. Brodsky, for the respondent.

TANNENWALD, Judge:

Respondent determined the following deficiencies in petitioners' Federal income tax:

   Year                              Deficiency

   1976 ......................... $91,707,185.00
   1977 .........................  10,584,794.00

After concessions by petitioners, the principal issue for decision is whether deposits collected and held by certain petitioners from certain customers were advance payments and...

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