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MYCO INDUSTRIES, INC. v. COMMISSIONER

Docket No. 7170-91.

98 T.C. 270 (1992)

MYCO INDUSTRIES, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 12, 1992.

Attorney(s) appearing for the Case

Karl Norman Clifford and Stephen J. Stone, for petitioner.

Martin M. Van Brauman, for respondent.

OPINION

BEGHE, Judge:

This opinion addresses respondent's motion under Rule 142(e)1 to allocate the burden of proof on the reasonableness of petitioner's alleged business needs for accumulated earnings tax purposes.

Petitioner is a corporation that has its principal place of business in Artesia, New Mexico, the same location it had at the time it filed its petition. Respondent determined that petitioner is liable...

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