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ALBERTSON'S, INC. v. COMMISSIONER

Docket No. 10439-87.

56 T.C.M. 928 (1988)

T.C. Memo. 1988-582

Albertson's, Inc. v. Commissioner.

United States Tax Court.

Filed December 27, 1988.

Attorney(s) appearing for the Case

Robert S. Erikson, Edwin V. Apel, Jr., Cathy R. Silak, and David A. Channer, One Capital Center, Boise, Idaho, for the petitioner. Joyce Britt, Julia Dewey, and Virginia Draper, for the respondent.

Memorandum Findings of Fact and Opinion

FAY, Judge:

Respondent determined a deficiency of $718,936 in Federal income tax for petitioner's taxable year ending February 3, 1983. The issue for decision is whether central heating, ventilating, and air-conditioning systems installed by petitioner in thirty-three of its stores qualified as section 381 property for investment tax credit purposes...

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