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INGRAM INDUSTRIES, INC. v. COMMISSIONER

Docket No. 14175-98.

80 T.C.M. 532 (2000)

T.C. Memo. 2000-323

Ingram Industries, Inc. & Subsidiaries v. Commissioner.

United States Tax Court.

Filed October 18, 2000.

Attorney(s) appearing for the Case

N. Jerold Cohen, Atlanta, Georgia, J.D. Fleming, Jr., Walter T. Henderson, Jr., Matthew J. Gries, and Walter H. Wingfield, for the petitioners. Bonnie L. Cameron and Vallie C. Brooks, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GERBER, Judge:

Respondent determined income tax deficiencies for petitioners' 1992, 1993, and 1994 tax years in the amounts of $1,315,659, $530,477, and $614,122, respectively. Respondent also determined increased interest for each year under section 6621(c).1 After agreements of the parties, the question we consider is whether the cost of the work performed on petitioners' towboat engines...

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