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SOUTHERN PACIFIC CO. v. COMMISSIONER

Docket No. 8648-72.

84 T.C. 395 (1985)

SOUTHERN PACIFIC COMPANY (FORMERLY S. P. INC.), 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 J. Becker, and Randall G. Dick, for the respondent.

OPINION

Background

JACOBS, Judge:*

This case is before the Court on petitioner's motion to dismiss for lack of jurisdiction. "Petitioners," as the word is used in this opinion, refers to Southern Pacific Co. (formerly S.P. Inc.) and a group of affiliated corporations.1

Prior to its dissolution on November 26, 1969, Southern...

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