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NESTLE HOLDINGS INC. v. COMMISSIONER

Docket No. 21562-90.

80 T.C.M. 829 (2000)

T.C. Memo. 2000-374

Nestle Holdings, Inc., on behalf of itself and Consolidated Subsidiaries, and as the successor in interest to Nestle Enterprises, Inc. and Consolidated Subsidiaries v. Commissioner.

United States Tax Court.

Filed December 12, 2000.

Attorney(s) appearing for the Case

Joseph R. Goeke, Thomas Kittle-Kamp, and John T. Hildy, for the petitioner. Theodore J. Kletnick, Paulette Segal, and Oleida Mendiburt, for the respondent.

SUPPLEMENTAL MEMORANDUM OPINION

VASQUEZ, Judge:

This matter is before the Court on the parties' disputed computations under Rule 155 of the decision to be entered for Nestle Holding Inc.'s (petitioner) 1983, 1984, and 1985 tax years.1 The ruling in this opinion relates solely to petitioner's 1985 tax year.2 The issue presented to us is whether the parties agreed in two settlement agreements on the...

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