International Multifoods Corporation and Affiliated Companies - Page 2

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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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