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POPE & TALBOT, INC. v. COMMISSIONER

Docket No. 530-93.

74 T.C.M. 471 (1997)

T.C. Memo. 1997-399

Pope & Talbot, Inc. and Subsidiaries v. Commissioner.

United States Tax Court.

Filed September 2, 1997.

Attorney(s) appearing for the Case

Grady M. Bolding, San Francisco, Calif., James E. Burns, Jr., Russell D. Uzes, Kevin P. Muck, and D. Cameron Baker, for the petitioner. Milton J. Carter, Jr., Terri Merriam, Henry T. Schaefer, Christopher D. Hatfield, Randall E. Heath, and Robert F. Geraghty, for the respondent.

SUPPLEMENTAL MEMORANDUM OPINION

RUWE, Judge:

The present dispute arises from the parties' differing computations under Rule 155.1

In our first opinion in this case, Pope & Talbot, Inc. and Subs. v. Commissioner [Dec. 50,629], 104 T.C. 574 (1995)(Pope & Talbot I), on motions for partial summary judgment, we held that under section 311(d), petitioner's gain on the distribution...

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