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DEERING MILLIKEN, INC. v. COMMISSIONER

Docket No. 7497-70.

59 T.C. 469 (1972)

DEERING MILLIKEN, INC., SUCCESSOR BY MERGER TO PACOLET INDUSTRIES, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 27, 1972.

Attorney(s) appearing for the Case

Jay W. Glasmann and Carol K. Nickel, for the petitioner.

Robert T. Hollohan and John H. W. Cole, for the respondent.

OPINION

TANNENWALD, Judge:

Respondent determined a deficiency of $138,024.29 in petitioner's income tax for the year ending November 29, 1964. The question presented is whether a corporation, created in a consolidation, is entitled to amortize as organizational expenditures under section 2481 the costs of an appraisal proceeding brought against it by stockholders of the consolidating corporations who dissented from the...

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