Cigarette Importer Sees $300,000,000 Deduction Go Up In Smoke

Last week, the Tax Court upheld an IRS deficiency notice of nearly forty million dollars against Vidal Suriel for the years 2004 and 2006.  The deficiencies relate to the timing of deductions for payments due under the Tobacco Master Settlement Agreement (MSA).  Mr. Suriel was the sole owner of Vibo Corp, which had made an S election.  Doing business as General Tobacco, Vibo sold less expensive cigarette brands such as GT-one, Bronco and Silver.  The company started selling cigarettes in 200...