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NORFOLK S. CORP. v. COMMISSIONER

Docket Nos. 19305-91, 19306-91.

104 T.C. 13 (1995)

NORFOLK SOUTHERN CORPORATION AND AFFILIATED COMPANIES, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 11, 1995.

Attorney(s) appearing for the Case

Newman T. Halvorson, Jr., Sean F. Foley, Frederick A. Richman, Andrew J. Frackman, Joseph G. Giannola, Richard Alan Brady, and William M. Paul, for petitioners.

Phillip A. Pillar, John A. Guarnieri, Stephen M. Miller, and Keith L. Gorman, for respondent.

PARR, Judge:

Respondent determined the following deficiencies in petitioners' Federal corporate income taxes, net of offsets for credits or refunds of overassessments of taxes to which respondent agrees petitioners are entitled:1

                                          Net
Year                                   deficiency
1981 ..............................    $8,274,876
1982 .................

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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