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INTERNATIONAL MULTIFOODS CORP. v. COMMISSIONER

Docket No. 11643-92.

108 T.C. 25 (1997)

INTERNATIONAL MULTIFOODS CORPORATION AND AFFILIATED COMPANIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 29, 1997.

Attorney(s) appearing for the Case

David R. Brennan, John K. Steffen, Susan B. Grupe, and Nathan P. Zietlow, for petitioner.

Jack Forsberg, for respondent.

RUWE, Judge:

Respondent determined deficiencies in petitioner's Federal income taxes as follows:

     TYE                          Deficiency

    2/28/87 .................     $2,962,380
    2/29/88 .................      3,592,402

Petitioner paid these deficiencies following receipt of its notice of deficiency and then filed a petition with this Court claiming an overpayment of income tax for each year. On December...

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