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TRIBUNE COMPANY v. COMMISSIONER

Docket No. 17443-02.

91 T.C.M. 678 (2006)

T.C. Memo. 2006-12

Tribune Company, as Agent Of and Successor by Merger to the Former the Times Mirror Company, Itself and its Consolidated Subsidiaries, v. Commissioner.

United States Tax Court.

Filed January 26, 2006.

Attorney(s) appearing for the Case

Joel V. Williamson, Roger J. Jones, Gary S. Colton, Jr., Jeffrey Allan Goldman, Matthew C. Houchens, Daniel A. Dumezich, Patricia Anne Rexford, Andrew R. Roberson, Thomas Lee Kittle-Kamp, Nathaniel Carden, and Monica Susana Melgarejo, for petitioner.

Alan Summers, Cathy A. Goodson, William A. McCarthy, Usha Ravi, Robert H. Schorman, Jr., and Gretchen A. Kindel, for respondent.

SUPPLEMENTAL MEMORANDUM OPINION

COHEN, Judge.

The supplemental opinion resolves the issue left undecided by our opinion in Tribune Co. v. Commissioner, 125 T.C. 110 (2005) (the Bender opinion). Pursuant to agreement of the parties, the issue involving the so-called "Mosby transaction" is submitted fully stipulated and decided on the basis of the Bender opinion. The findings of fact set forth in the Bender opinion are...

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