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ALLEN FAMILY FOODS, INC. v. COMMISSIONER

Docket Nos. 18546-99, 18547-99.

80 T.C.M. 562 (2000)

T.C. Memo. 2000-327

Allen Family Foods, Inc., Charles C. Allen III, Tax Matters Person v. Commissioner. Allen's Hatchery, Inc., John R. Allen, Jr., Tax Matters Person v. Commissioner.

United States Tax Court.

Filed October 20, 2000.

Attorney(s) appearing for the Case

Robert H. Knapp, Washington, D.C., and John S. Stanton, for the petitioners. Clare J. Brooks and Ronald L. Buch, Jr., for the respondent.

MEMORANDUM OPINION

ARMEN, Special Trial Judge:

These cases are before the Court on respondent's Motions to Dismiss for Lack of Jurisdiction and to Strike. Respondent contends that the Court lacks jurisdiction in these corporate level proceedings to consider allegations contained in the petitions regarding: (1) The impact (if any) of the underlying adjustments on shareholder basis and (2) the accuracy-related penalty...

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