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PPL CORP. & SUBS. v. COMMISSIONER

Docket No. 25393-07.

135 T.C. 176 (2010)

PPL CORPORATION & SUBSIDIARIES, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed July 28, 2010.

Attorney(s) appearing for the Case

Richard E. May, Mark B. Bierbower, and Timothy L. Jacobs, for petitioner.

Melissa D. Arndt, Allan E. Lang, Michael C. Prindible, and R. Scott Shieldes, for respondent.

HALPERN, Judge:

PPL Corp. (petitioner) is the common parent of an affiliated group of corporations (the group or affiliated group) making a consolidated return of income. By notice of deficiency (the notice), respondent determined a deficiency of $10,196,874 in the group's Federal income tax for its 1997 taxable (calendar) year and also denied a claim for refund of $786,804. The issues for decision are whether respondent...

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