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BOWATER INCORPORATED v. COMMISSIONER

Docket No. 18436-91.

69 T.C.M. 2382 (1995)

T.C. Memo. 1995-164

Bowater Incorporated, f.k.a. Bowater Holdings, Inc., and Subsidiaries v. Commissioner.

United States Tax Court.

Filed April 10, 1995.

Attorney(s) appearing for the Case

Robert T. Carney, 1737 "H" St., N.W., Washington, D.C., for the petitioner. Stephen M. Miller, for the respondent.

Memorandum Opinion

RAUM, Judge:

The Commissioner determined deficiencies in petitioner's Federal income tax totaling $3,231,988 for 1976, $5,214,010 for 1979, and $27,096,396 for 1980. The issue for decision is whether amounts denoted as interest were properly deducted under section 1631 or were actually dividends. The interest at issue was paid on declared but unpaid dividends, and totaled $2,444,229 in 1979 and $2,239,170 in...

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