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David R. Brennan, John K. Steffen, Susan B. Grupe, and
Nathan P. Zietlow, for petitioner.
Jack Forsberg, for respondent.
RUWE, Judge: On March 26, 1992, respondent determined
deficiencies in petitioner's Federal income taxes as follows:
Taxable Year Ended Deficiency
Feb. 28, 1987 $2,962,380
Feb. 29, 1988 3,592,402
Petitioner paid these deficiencies following receipt of its
notice of deficiency and on June 1, 1992, filed a petition with
this Court claiming an overpayment of income tax for each year.
In International Multifoods Corp. v. Commissioner, 108 T.C.
25 (1997), we disposed of several issues in this case. In an
order accompanying the release of our opinion, we granted
respondent's motion to sever and hold the sole remaining issue in
abeyance. This remaining issue requires us to decide whether the
loss realized by petitioner on its sale of the stock of Paty
S.A.-Produtos Alimenticios, Ltda.,1 on March 31, 1987, is to be
sourced in the United States for purposes of computing
1Hereinafter, we shall refer to Paty S.A.-Produtos
Alimenticios, Ltda., as Paty and to the issue in question as the
Paty stock loss issue.
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