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The deficiencies stem from Griffin's sale of certain stock
to GNN. We must determine whether this sale occurred in 1981 or
1989. GNN argues that the sale occurred in 1981. Griffin and
respondent argue that the sale occurred in 1989. We hold that
the sale occurred in 1989.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations and exhibits submitted therewith are
incorporated herein by this reference. Griffin and GNN are
corporations whose principal places of business were in New York,
New York, and Atlanta, Georgia, respectively, when they
petitioned the Court.
Griffin is the successor to Leaf River Paper Co. (LRPC).
LRPC was organized in 1971 under the laws of Delaware, and it
changed its name to Griffin in 1982 (hereinafter we refer to LRPC
as Griffin.) Griffin's sole shareholder is a Finnish company
named Kymi Kymmene Oy (KKO). KKO is one of the largest forest
product companies in Finland; it produces and sells in Europe
forest products such as pulp and paper products. KKO organized
Griffin as a nonoperating holding company to manage KKO's
interests in the United States. Until December 31, 1981, Griffin
had a wholly owned subsidiary named Leaf River Forest Products,
Inc. (LRFP), which was formed in 1975 to own and operate a
sawmill in New Augusta, Mississippi.
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