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ARMCO, INC. v. COMMISSIONER

Docket Nos. 20037-85, 45229-85.

87 T.C. 865 (1986)

ARMCO, INC. FORMERLY ARMCO STEEL CORPORATION AND SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT ARMCO, INC. AND SUBSIDIARIES, FORMERLY ARMCO STEEL CORPORATION AND SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 28, 1986.

Attorney(s) appearing for the Case

James P. Holden, Kenneth I. Jonson and Joseph P. Esposito, for the petitioner.

Joseph R. Goeke, for the respondent.

OPINION

WILLIAMS, Judge:

Petitioner seeks a ruling prior to trial on the admissibility of an affidavit of a former employee of the Department of Treasury and the Internal Revenue Service who assisted in drafting section 1.167(a)-11(d)(2), Income Tax Regs. The proper application of this section of the regulations, particularly example (2) of section 1.167(a)-11(d)(2)(vi), Income Tax Regs., is one of the issues...

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