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NATIONAL STARCH & CHEMICAL CORP. v. COMMISSIONER

Docket No. 31669-84.

93 T.C. 67 (1989)

NATIONAL STARCH AND CHEMICAL CORP., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 24, 1989.

Attorney(s) appearing for the Case

Richard J. Hiegel, Leonard E. Kust, Richard H. Walker, and Geoffrey R.S. Brown, for the petitioner.

Richard J. Sapinski, Daniel Morman, Paul J. Sude, and Janet A. Engel, for the respondent.

CLAPP, Judge:

Respondent determined a deficiency in petitioner's Federal income tax for the taxable year ended August 15, 1978, in the amount of $1,068,281. The only issue for our decision is whether petitioner, the acquired corporation in a friendly takeover, may deduct under section 162(a)1 the expenditures it incurred incident to the takeover.

FINDINGS OF FACT

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