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POPE & TALBOT, INC. v. COMMISSIONER

Docket No. 530-93.

73 T.C.M. 2229 (1997)

T.C. Memo. 1997-116

Pope & Talbot, Inc., & Subsidiaries v. Commissioner.

United States Tax Court.

Filed March 6, 1997.

Attorney(s) appearing for the Case

Grady M. Bolding, San Francisco, Calif., James E. Burns, Jr., Russell D. Uzes, Kevin P. Muck, and D. Cameron Baker, for the petitioner. Milton J. Carter, Jr., Terri Merriam, Henry T. Schaefer, Christopher D. Hatfield, Randall E. Heath, and Robert F. Geraghty, for the respondent.

MEMORANDUM OPINION

RUWE, Judge:

Respondent determined deficiencies in petitioner's 1985 and 1986 Federal income taxes in the amounts of $17,693,960 and $954,678, respectively. In Pope & Talbot, Inc. & Subs. v. Commissioner [Dec. 50,629], 104 T.C. 574 (1995), we denied petitioner's motion for partial summary judgment and granted respondent's motion for partial summary judgment, holding that under section 311...

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