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C.H. ROBINSON, INC. v. COMMISSIONER

Docket Nos. 9730-96, 26811-96.

76 T.C.M. 969 (1998)

T.C. Memo. 1998-430

C.H. Robinson, Inc. and Subsidiaries v. Commissioner. C.H. Robinson, Inc. v. Commissioner.

United States Tax Court.

Filed December 8, 1998.

Attorney(s) appearing for the Case

William J. Hippee, Jr., Minneapolis, Minnesota, and David B. Strong, for the petitioners in Docket Nos. 9730-96 and 26811-96.

Edward J. Plumier, for the petitioner in Docket No. 9730-96.

Jack Forsberg, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

SWIFT, Judge.

For the years in issue, respondent determined deficiencies in petitioners' consolidated Federal income taxes as follows:

Year                                   Deficiency

1990 ...............................    $275,348
1991 ...............................     494,345
1992 ...............................      21,320

For 1992, petitioners claim an overpayment...

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