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WINN-DIXIE STORES, INC. & SUBS. v. COMMISSIONER

Docket Nos. 26236-95, 27027-96, 5382-97.

110 T.C. 291 (1998)

WINN-DIXIE STORES, INC. AND SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 27, 1998.

Attorney(s) appearing for the Case

Michael J. Henke, Tegan M. Flynn, Cary D. Pugh, and Thomas Crichton IV, for petitioner.

Nancy B. Herbert and Donna P. Leone, for respondent.

OPINION

RUWE, Judge:

This matter is before the Court on petitioner's motion for partial summary judgment filed January 9, 1998, pursuant to Rule 121.1 These consolidated cases involve petitioner's taxable years 1988 through 1993.2

As a preliminary matter, we must decide whether this Court has jurisdiction to determine whether petitioner has made overpayments for 1988 through 1991 based...

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