Tate & Lyle, Inc. and Subsidiaries - Page 1

                                 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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