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SOUTHERN PACIFIC TRANSPORTATION v. COMMISSIONER

Docket No. 8647-72.

84 T.C. 387 (1985)

SOUTHERN PACIFIC TRANSPORTATION COMPANY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 12, 1985.

Attorney(s) appearing for the Case

Arnold I. Weber, Alan S. Beinhorn, and William E. Saul, for the petitioner.

Peter D. Bakutes, James Booher, Vernon R. Balmes, Bernard Plamer, Lawrence G. Becker, and Randall G. Dick, for the respondent.

OPINION

Background

JACOBS, Judge:*

This case is before the Court on Southern Pacific Transportation Company's ("Transportation") motion to dismiss for lack of jurisdiction.1 Transportation instituted this proceeding in its capacity as transferee of the assets of Southern Pacific Co. (former Southern Pacific), the common parent of an...

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