Memorandum Opinion
HAMBLEN, Judge:
The sole issue before the Court for its determination is whether leave should be granted respondent to amend his answer to provide for the imposition of interest on substantial underpayments attributable to tax motivated transactions pursuant to section 6621(d).
Petitioner, a U.S. (Delaware) corporation with its principal corporate office in Rockford, Illinois, is a publicly-held corporation...
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