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GULF OIL CORP. v. COMMISSIONER

Docket No. 22499-82.

86 T.C. 115 (1986)

GULF OIL CORPORATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 30, 1986.

Attorney(s) appearing for the Case

J. Waddy Bullion, Emily A. Parker, Sean T. Crimmins, Buford P. Berry, J. Y. Robb III, and Margaret S. Alford, for the petitioner.

Raymond L. Collins and William B. Lowrance, for the respondent.

GOFFE, Judge:

The Commissioner determined deficiencies in petitioner's Federal income tax for the taxable year 1974 in the amount of $80,813,428 and for the taxable year 1975 in the amount of $166,316,320. Petitioner and respondent, by motion granted on November 10, 1983, agreed that certain issues would be severed and tried at a special trial session which was held at Dallas, Texas.

One of the issues tried...

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