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PHILIP MORRIS INC. v. COMMISSIONER

Docket Nos. 28604-82, 33778-83, 38953-84.

96 T.C. 606 (1991)

PHILIP MORRIS INCORPORATED AND CONSOLIDATED SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 11, 1991.

Attorney(s) appearing for the Case

Jerome B. Libin, William S. Corey, Padric K.J. O'Brien, Richard A. Burton, and James Randall Buchanan, for the petitioner.

Lewis R. Mandel, Diane R. Mirabito, and Steven M. Diamond, for the respondent.

JACOBS, Judge:

Respondent determined deficiencies in petitioner's Federal income tax as follows:

     TYE                                           Deficiency

   12/31/78 ..................................    $52,056,108
   12/31/79 ..................................     44,316,979
   12/31/80 ..................................     59,024,150

Following concessions, the primary issue for decision is the fair market...

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