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LOUISIANA LAND & EXPLOR. CO. & SUBSIDIARIES v. COMMISSIONER

Docket No. 10246-89.

102 T.C. 21 (1994)

LOUISIANA LAND AND EXPLORATION COMPANY AND SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 19, 1994.

Attorney(s) appearing for the Case

William M. Linden, David B. Gerger, Thomas Crichton IV, Margaret A. Wilson, and Henry Binder, for petitioner.*

Thomas R. Ascher, Patrick Putzi, and Marsha A. Keyes, for respondent.

CLAPP, Judge:

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

  Year                                        Deficiency

  1984 ...................................    $36,646,062
  1985 ...................................      3,615,049

After concessions, the issues for decision are: (1) Whether the nonmaterial costs of fabricating certain modules that are structural components...

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