United States Tax Court.
Memorandum Findings of Fact and Opinion
PARR, Judge:
Respondent determined deficiencies in petitioner's Federal income tax of $156,043, $191,868 and $171,222 in 1979, 1982, and 1983, respectively.
The primary issue for decision is whether petitioner may deduct certain preopening expenses of its wholly owned subsidiaries as ordinary and necessary business expenses under section 162.
Findings of Fact
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