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LIGGETT GROUP, INC. v. COMMISSIONER

Docket No. 28427-84.

58 T.C.M. 1167 (1990)

T.C. Memo. 1990-18

Liggett Group, Inc., Successor in Interest to Liggett & Myers, Incorporated & Consolidated Subsidiaries v. Commissioner.

United States Tax Court.

Filed January 11, 1990.

Attorney(s) appearing for the Case

William F. Indoe, John L. Warden, Elise A. Bloustein, and Elliot M. Maza, 125 Broad St., N.Y., for the petitioner. Paul G. Topolka, for the respondent.

Memorandum Findings of Fact and Opinion

WRIGHT, Judge:

By notice of deficiency dated May 25, 1984, respondent determined deficiencies in petitioner's Federal income tax as follows:

   Taxable Year Ending                 Deficiencies

   December 31, 1971 ................  $ 69,294
   December 31, 1972 ................   864,644
   December 31, 1973 ................   798,702

By an amendment to his answer, respondent...

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