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TOWER LOAN OF MISSISSIPPI, INC. v. COMMISSIONER

Docket No. 570-93.

71 T.C.M. 2581 (1996)

T.C. Memo. 1996-152

Tower Loan of Mississippi, Inc. v. Commissioner.

United States Tax Court.

Filed March 26, 1996.

Attorney(s) appearing for the Case

Leonard D. Van Slyke, Jr., Jackson, Miss., and Denise F. Schreiber (specially recognized), for the petitioner. Thomas R. Ascher and Kim A. Palmerino, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

PARR, Judge:

Respondent determined deficiencies in petitioner's Federal income tax for 1988 and 1989 of $370,317 and $490,267, respectively.

The issues for decision are: (1) Whether certain commission income should be reallocated to petitioner from petitioner's wholly owned subsidiary pursuant to section 482.1 We hold that it should not. (2) Whether petitioner can take a bad debt...

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