Court of Appeals for the Ninth Circuit March 30, 1981, 78-3104 (Bercy Industries, Inc., and Subsidiaries v. Commissioner of Internal Revenue)

TRASK, Circuit Judge:

Appellant Bercy Industries, Inc. (Bercy), appeals from a decision of the Tax Court

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affirming a deficiency assessment by the Commissioner of Internal Revenue (the Commissioner). This court has jurisdiction pursuant to I.R.C. [26 U.S.C.] § 7482.