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HONEYWELL INC. v. COMMISSIONER

Docket No. 15807-83.

87 T.C. 624 (1986)

HONEYWELL INC. AND SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 22, 1986.

Attorney(s) appearing for the Case

Clinton A. Schroeder, David C. Bahls, and Myron L. Frans, for the petitioner.

James F. Kidd, for the respondent.

OPINION

COHEN, Judge:

Respondent determined deficiencies of $1,592,852 and $9,542,483 in petitioner's Federal income taxes for 1976 and 1977, respectively. Certain of the adjustments in the statutory notice of deficiency have been resolved by agreement, and all of the facts have been stipulated. Three issues remain to be resolved on cross motions for partial summary judgment. They are:

(1) Whether...

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