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RALSTON PURINA CO. & SUBS. v. COMMISSIONER

Docket No. 7357-00.

131 T.C. 29 (2008)

RALSTON PURINA COMPANY & SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed September 10, 2008.

Attorney(s) appearing for the Case

Kenneth A. Kleban, for petitioner.

Lawrence C. Letkewicz and Dana E. Hundrieser, for respondent.

OPINION

NIMS, Judge:

Before the Court are petitioner's and respondent's cross-motions for summary judgment pursuant to Rule 121.

Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure, and all section references are to the Internal Revenue Code in effect for the years in issue.

Rule 121(a) provides that either party may move for summary judgment upon all or any part of the legal issues...

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