United States Tax Court June 6, 1990, Docket No. 24080-88 (Nestle Holdings, Inc. v. Commissioner)

OPINION

GOFFE, Judge:

The case is presently before us on cross-motions for partial summary judgment under Rule 121(b).1 There is no genuine issue as to any material fact with respect to the question presented.

The Commissioner determined the following deficiencies in, and additions to, petitioner’s Federal income taxes:

TYE Deficiency Addition to tax Sec.