United States Tax Court July 17, 2000, No. 3110-98 (Tutor-Saliba Corp. v. Commissioner)

lead-opinion

Gerber, Judge:

Pursuant to Rule 121,1 this matter is before the Court on petitioner’s motion for partial summary-judgment. The parties seek to determine, as a matter of law, whether section 1.460-6(c)(2)(vi)(A) and (B), Income Tax Regs.