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HACHETTE USA, INC. v. COMMISSIONER

Docket Nos. 11693-94, 11694-94.

105 T.C. 234 (1995)

HACHETTE USA, INC., AS SUCCESSOR TO HACHETTE PUBLICATIONS, INC., AND CURTIS CIRCULATION CO., SUBSIDIARY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT HACHETTE USA, INC., AS SUCCESSOR TO HACHETTE DISTRIBUTION, INC., AND CURTIS CIRCULATION CO., SUBSIDIARY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 25, 1995.

Attorney(s) appearing for the Case

Daniel M. Davidson and John Wester, for petitioners.

John A. Guarnieri and Douglas A. Fendrick, for respondent.

OPINION

LARO, Judge:

These cases were consolidated for trial, briefing, and opinion, and submitted to the Court without trial pursuant to Rule 122(a).1 Hachette USA, Inc. (Hachette USA), and its subsidiary Curtis Circulation Co. (Curtis) petitioned the Court for redetermination of the following Federal income tax deficiencies determined by respondent:

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