Court of Appeals for the Eighth Circuit August 21, 1990, 89-2148 (Carland, Inc. v. Commissioner of Internal Revenue)

LAY, Chief Judge.

Carland, Inc. (Carland) appeals the Tax Court’s decision upholding income tax deficiencies assessed by the Commissioner of Internal Revenue (Commissioner) for the years 1970-1975. The Tax Court sustained deficiencies in the following,amounts: 1970 —$586,844; 1971 — $480,858; 1972 — $212,-449; 1973 — $37,128; 1974 — $36,420; 1975 —$11,227. We affirm in part and reverse in part.

I.