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FRERES LUMBER CO. v. COMMISSIONER

Docket No. 16062-93.

70 T.C.M. 1549 (1995)

T.C. Memo. 1995-589

Freres Lumber Co., Inc. v. Commissioner.

United States Tax Court.

Filed December 13, 1995.

Attorney(s) appearing for the Case

Philip N. Jones, Ore., Stephen J. Klarquist, and Richard W. Miller, for the petitioner. Brenda M. Fitzgerald, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge:

Respondent determined that petitioner had deficiencies in Federal income tax of $29,750 for 1988, $40,732 for 1989, and $51,119 for 1990. In an amended answer, respondent asserts that petitioner has deficiencies in Federal income tax of $43,787 for 1988, $64,689 for 1989, and $74,786 for 1990. After concessions, we must decide the following issues:

1. Whether the fair market value of three covenants...

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