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HUMANA INC. v. COMMISSIONER

Docket Nos. 15292-80, 17130-82.

50 T.C.M. 784 (1985)

T.C. Memo. 1985-426

Humana Inc. and Subsidiaries v. Commissioner.

United States Tax Court.

Filed August 14, 1985.

Attorney(s) appearing for the Case

James E. Milliman, Charles J. Lavelle, Arthur Hipwell, for the petitioners. Joel V. Williamson, Scott R. Cox, for the respondent.

Memorandum Findings of Fact and Opinion

KÖRNER, Judge:

Respondent determined deficiencies against petitioners, Humana Inc. and subsidiaries, as follows:

                 Tax year
Docket No.        ended      Deficiency

15292-80 .....   8/31/76     $ 4,615,905
                 8/31/77       9,409,814
17130-82 .....   8/31/78       7,723,542
                 8/31/79      20,460,078

After concessions, the sole issue for decision...

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