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DAYTON HUDSON CORPORATION v. COMMISSIONER

Docket No. 21217-91.

73 T.C.M. 2978 (1997)

T.C. Memo. 1997-260

Dayton Hudson Corporation and Subsidiaries v. Commissioner.

United States Tax Court.

Filed June 11, 1997.

Attorney(s) appearing for the Case

David R. Brennan, Minneapolis, Minn., and Walter A. Pickhardt, for the petitioner. Reid M. Huey, John C. Schmittdiel, Robert J. Kastl, and Robin L. Herrell, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

HALPERN, Judge:

Respondent has determined a deficiency in petitioner's Federal income tax for its 1984 taxable year in the amount of $17,384,314, and petitioner has claimed an overpayment of income tax for that taxable year in the amount of $180,375.1

Previously, on respondent's motion for summary judgment, we addressed one of the issues presented in this case. In Dayton Hudson...

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