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RJR NABISCO INC. v. COMMISSIONER

Docket No. 3796-95.

76 T.C.M. 71 (1998)

T.C. Memo. 1998-252

RJR Nabisco Inc. (Formerly R.J. Reynolds Industries, Inc.) and Consolidated Subsidiaries. v. Commissioner.

United States Tax Court.

Filed July 8, 1998.

Attorney(s) appearing for the Case

Wayne S. Kaplan, Chicago, Ill., William Albert Schmalzl, Thomas Kittle-Kamp, Clifford S. Rexford and Stephen D. Katzman, for the petitioner. Kim A. Palmerino and Gary Walker, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

HALPERN, Judge:

Petitioner is the common parent corporation of an affiliated group of corporations making a consolidated return of income (the affiliated group). By notice of deficiency dated December 15, 1994 (the notice), respondent determined a deficiency in Federal income tax for the affiliated group for its 1982 taxable (calendar) year in the amount of $9,856,982.76 along with an increased rate of interest under...

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