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J.E. SEAGRAM CORP. v. COMMISSIONER

Docket No. 6112-92.

104 T.C. 75 (1995)

J.E. SEAGRAM CORP., F.K.A. SEAGOLD VINEYARDS HOLDING CORPORATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 24, 1995.

Attorney(s) appearing for the Case

Harold R. Handler and David W. Ichel, for petitioner.

Anne Hintermeister and William H. Stoddard, for respondent.

OPINION

NIMS, Judge:

Respondent determined a deficiency in Federal income tax with respect to petitioner's fiscal year ended July 31, 1982, in the amount of $160,127,325. Respondent also determined deficiencies for withholding of income tax at source in the following amounts:

                                               Withholding
Calendar year                                   deficiency
1982 ..................

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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