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RIO GRANDE HOLDING, INC. v. COMMISSIONER

Docket No. 1098-93.

67 T.C.M. 3022 (1994)

T.C. Memo. 1994-240

Rio Grande Holding, Inc., f.k.a. Rio Grande Industries, Inc., and Subsidiaries v. Commissioner.

United States Tax Court.

May 26, 1994.

Attorney(s) appearing for the Case

William E. Saul and Alfred P. Paladino, One Market Plaza, San Francisco, Calif., for the petitioner. Emron M. Pratt, Jr. and Lana Eckhardt, for the respondent.

Memorandum Opinion

RUWE, Judge:

This matter is before the Court on petitioner's motion to dismiss for lack of jurisdiction.

Respondent determined deficiencies in tax and an addition to tax as follows:

                                      Addition to Tax
     TYE                 Deficiency      Sec. 6661

Dec. 31, 1980 .......   $ 3,141,362         --
Dec. 31, 1983 .......        78,758      $19,690
Oct...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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