T.C. Memo. 1996-80
UNITED STATES TAX COURT
TATE & LYLE, INC. AND SUBSIDIARIES, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 26352-93, 16170-94. Filed February 26, 1996.
Henry B. Miller, for petitioner.
Darrell C. Weaver, for respondent.
MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge: These cases were
assigned pursuant to the provisions of section 7443A(b)(4) and
Rules 180, 181, and 183.1 These cases are before the Court on
1 All section references are to the Internal Revenue Code,
as amended, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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