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S-K LIQUIDATING CO. v. COMMISSIONER

Docket No. 1798-74.

64 T.C. 713 (1975)

S-K LIQUIDATING CO. (FORMERLY SKAGIT CORPORATION AND SUBSIDIARY), PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed July 30, 1975.

Attorney(s) appearing for the Case

James Wm. Johnston, William R. Smith, and Dwight J. Drake, for the petitioner.

Matthew W. Stanley, Jr., for the respondent.

OPINION

HALL, Judge:

Respondent determined a deficiency of $384,677 for S-K Liquidating Co.'s taxable year ended October 31, 1969. This matter is before us on petitioner's preliminary motion for judgment on the pleadings pursuant to Rule 120, Tax Court Rules of Practice and Procedure. The immediate issue for resolution is whether respondent is precluded from asserting the current deficiency because of an earlier Tax Court decision which petitioner...

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