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WEGMAN'S PROPERTIES, INC. v. COMMISSIONER

Docket No. 6655-79.

78 T.C. 786 (1982)

WEGMAN'S PROPERTIES, INC., AND SUBSIDIARIES, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 5, 1982.

Attorney(s) appearing for the Case

Paul S. Speranza, Jr., for the petitioners.

Kenneth Bersani, for the respondent.

OPINION

TANNENWALD, Chief Judge:

Respondent determined deficiencies in petitioners' Federal income tax of $25,883.47 for the taxable year ended June 24, 1972, and $24,023.10 for the taxable year ended June 30, 1973. The sole issue for our determination is whether, for purposes of computing petitioners' minimum tax liability, tax carryovers generated by one corporation in preaffiliation years1 may be used to offset items...

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