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VICTORY MARKETS, INC. v. COMMISSIONER

Docket No. 11276-90.

99 T.C. 648 (1992)

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

United States Tax Court.

Filed December 23, 1992.

Attorney(s) appearing for the Case

Michael J. Sarofeen and Thomas S. Brett, for petitioner.

Randall P. Andreozzi, for respondent.

OPINION

GERBER, Judge:

Respondent determined deficiencies in Federal income tax due from petitioner for its 1980, 1983, and 1984 taxable years in the amounts of $998, $184,099, and $63,320, respectively. The deficiencies determined result from adjustments respondent made disallowing net operating loss carrybacks from petitioner's short taxable years ending July 8, 1986, and December 27, 1986. In its short...

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