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INTERNATIONAL TELEPHONE & TELEGRAPH CORP. v. COMMISSIONER

Docket No. 7990-75.

77 T.C. 1367 (1981)

INTERNATIONAL TELEPHONE & TELEGRAPH CORPORATION AND AFFILIATED COMPANIES, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 31, 1981.

Attorney(s) appearing for the Case

Stephen D. Gardner, for the petitioners.

Julius A. Jove, for the respondent.

SUPPLEMENTAL OPINION

TANNENWALD, Chief Judge:

The original opinion in this proceeding, International Telephone & Telegraph v. Commissioner, 77 T.C. 60, was issued on July 9, 1981. In that opinion, we held that petitioners had not met their burden of proof as to whether any loss was realized by ITT Aetna Finance Co. (ITT Aetna) or ITT Avis, Inc. (ITT Avis), on the retirement of Avis, Inc. (Avis), and Aetna...

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