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VANALCO, INC. v. COMMISSIONER

Docket No. 5955-98.

78 T.C.M. 251 (1999)

T.C. Memo. 1999-265

Vanalco, Inc., A Delaware S Corporation, Richard L. Smith, Tax Matters Person v. Commissioner.

United States Tax Court.

Filed August 6, 1999.

Attorney(s) appearing for the Case

Richard L. Mull, Seattle, Wash., and Ronald L. Berenstain, for the petitioner.

William A. McCarthy and Kenneth P. Dale, for the respondent.

MEMORANDUM OPINION

PARR, Judge.

Respondent issued two notices of final S corporation administrative adjustment (FSAA) to the tax matters person of Vanalco, Inc. (Vanalco), determining adjustments of $4,325,463 and $2,930,758 to the ordinary income of Vanalco for 1992 and 1993, respectively. After a concession,1 the issues for decision are: (1) Whether Vanalco may deduct or must capitalize the costs of replacing the linings of...

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