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NAPP SYSTEMS, INC. v. COMMISSIONER

Docket No. 16122-90.

65 T.C.M. 2567 (1993)

T.C. Memo. 1993-196

Napp Systems, Inc., f.k.a. Napp Systems (USA), Inc. v. Commissioner.

United States Tax Court.

Filed May 4, 1993.

Attorney(s) appearing for the Case

Richard A. Davidson and James A. Mezvinsky, 600 Davenport Bk. Bldg., Davenport, Iowa, for the petitioner. William A. Eddy and Mark E. O'Leary, for the respondent.

Memorandum Findings of Fact and Opinion

SHIELDS, Judge:

Respondent determined a deficiency in petitioner's Federal income tax for the year ended September 30, 1984, in the amount of $90,390.42. After concessions, the only issue remaining for decision is whether petitioner correctly calculated its commission expense deduction under section 9941 and section 1.994-1(c) and (d), Income Tax Regs.

Findings of Fact

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