United States Tax Court July 12, 2000, 12955-96 (TOMEN POWER CORP. v. COMMISSIONER OF INTERNAL REVENUE)

TOMEN POWER CORPORATION and Includible Subsidiaries, f.k.a. Toyo Construction Company and Subsidiaries, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. TOMEN POWER CORP. v. COMMISSIONER OF INTERNAL REVENUE 12955-96 United States Tax Court 2000 U.S. Tax Ct. LEXIS 98; July 12, 2000, Entered *98 CAMERON W. WOLFE, Jr., Counsel for Petitioner, San Fransicso, CA. PAUL R.