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UNION PACIFIC CORP. v. COMMISSIONER

Docket No. 24152-81.

91 T.C. 32 (1988)

UNION PACIFIC CORPORATION AND AFFILIATED COMPANIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 18, 1988.

Attorney(s) appearing for the Case

James P. Holden, Susan H. Serling, and J. Walker Johnson, for the petitioner.

Lewis R. Carluzzo, for the respondent.

OPINION

TANNENWALD, Judge:

Respondent determined the following deficiencies in petitioner's Federal income tax:

      Year                                   Deficiency

      1975 ................................  $4,072,046
      1976 ................................   5,509,231
      1977 ................................  45,869,744

After concessions by the parties, the issues for decision are whether petitioner...

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