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B.T.A. 906 (1937), and Rudolph Wurlitzer Co. v. Commissioner, 81
F.2d 971 (6th Cir. 1936), affg. 29 B.T.A. 443 (1933)), on which
both parties rely was whether the stock in question was voting
stock or nonvoting stock for purposes of the applicable consoli-
dation provisions. Those cases did not even address how to
measure the voting power possessed by different classes of voting
stock for purposes of those provisions. The questions presented
in certain of the rulings on which both parties rely (viz, Rev.
Rul. 69-126, 1969-1 C.B. 218; I.T. 3896, 1948-1 C.B. 72) were
whether the stock in question was voting stock or nonvoting stock
for purposes of the applicable consolidation provisions and how
to measure the voting power possessed by different classes of
voting stock for purposes of those provisions. One or both of
those issues also were involved in certain of the other rulings
on which petitioners rely (e.g., Rev. Rul. 71-83, 1971-1 C.B.
268; Priv. Ltr. Rul. 90-26-047 (Mar. 30, 1990); Priv. Ltr. Rul.
83-42-014 (July 10, 1983); Priv. Ltr. Rul. 82-21-112 (Feb. 26,
1982)).
None of the cases or rulings on which petitioners rely
involved the facts presented in the instant case. Nor does any
of them mandate that we adopt petitioners' espoused mechanical
test, let alone their application of that test, in determining in
the present case whether the Alumax class C common stock owned by
the Amax group stockholders satisfies the voting power require-
ment of section 1504(a)(1) and amended section 1504(a)(1)(B) and
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