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BTR DUNLOP HOLDINGS, INC. v. COMMISSIONER

Docket No. 24140-97.

78 T.C.M. 797 (1999)

T.C. Memo. 1999-377

BTR Dunlop Holdings, Inc. and Subsidiaries v. Commissioner.

United States Tax Court.

Filed November 15, 1999.

Attorney(s) appearing for the Case

Michael F. Solomon, Washington, D.C., Clifton B. Cates III, Alan W. Granwell, and Dirk J.J. Suringa, for the petitioner. Alan R. Peregoy, Gary D. Kallevang, and Judith C. Cohen, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COHEN, Chief Judge:

Respondent determined a deficiency of $11,202,042 in petitioner's Federal income tax for 1989. The issues for decision are as follows:

(1) What was the value of Schlegel U.K. Holdings, Ltd. (Schlegel UK), and Schlegel GmbH on July 1, 1989, and November 30, 1989, respectively, for purposes of section 311(b) and section 482 and

(2) what was the Schlegel Corporation's adjusted tax basis...

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