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MARTIN ICE CREAM CO. v. COMMISSIONER

Docket No. 1477-93.

110 T.C. 189 (1998)

MARTIN ICE CREAM COMPANY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 17, 1998.

Attorney(s) appearing for the Case

Frank Agostino, Alan G. Merkin, Mary Ann Perrone, and Susan M. Flynn, for petitioner. Patricia Y. Taylor and Clare W. Darcy, for respondent.

BEGHE, Judge:

Respondent determined the following deficiency and additions to tax:

                                   Additions to tax

    Year      Deficiency    Sec. 6653(a)(1)     Sec. 6661

    1988       $477,816       $23,891             $119,454

In so doing, respondent determined that Martin Ice Cream Co. (MIC or petitioner) recognized taxable gain of $1,430,340 on the distribution of stock...

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