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KLUKWAN, INC. v. COMMISSIONER

Docket No. 14342-92.

68 T.C.M. 446 (1994)

T.C. Memo. 1994-402

Klukwan, Inc. and Subsidiaries v. Commissioner.

United States Tax Court.

Filed August 18, 1994.

Attorney(s) appearing for the Case

John T. Piper, Don Paul Badgley, and Kay Sirlin Slonim, 601 Union St., Seattle, Wash., for the petitioner.* Wendy S. Pearson, Henry Thomas Schaefer, Christopher D. Hatfield, Terri A. Merriam, Randall E. Heath, and Robert F. Geraghty, for the respondent.

Memorandum Findings of Fact and Opinion

KORNER, Judge:

Respondent determined a deficiency in petitioner's Federal income tax in the amount of $6,921,356 for 1988.

All statutory references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, except as otherwise noted.

Questions Presented

After the settlement of various controversies...

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