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At the time the petition was filed, petitioner's principal
place of business was Des Moines, Iowa.
A motion for summary judgment or for partial summary
judgment may be granted if no genuine issue of material fact
exists and the decision can be rendered as a matter of law. Rule
121; Sundstrand Corp. & Consol. Subs. v. Commissioner, 98 T.C.
518, 520 (1992), affd. 17 F.3d 965 (7th Cir. 1994); Shiosaki v.
Commissioner, 61 T.C. 861, 862-863 (1974). In their respective
Statements of Undisputed Facts, the parties have agreed to fully
incorporate the stipulation of facts that is part of the record
in Meredith Corp. & Subs. v. Commissioner, 102 T.C. 406 (1994)
(Meredith I). The parties have also agreed to fully incorporate
the facts as set forth in the Court's Opinion in Meredith I.
This reference incorporates herein the Statements of Undisputed
Facts and attached exhibits. As such, there is no genuine issue
of material fact, and this matter is ripe for resolution by means
of summary judgment. We shall repeat the facts as necessary to
clarify the ensuing discussion.
Background
Meredith Corporation (petitioner or Meredith) was organized
in 1902. It is a diversified media company involved in magazine
and book publishing, television broadcasting, real estate
marketing, franchising, and until recently, printing. Meredith
has continued to expand its operations in the media industry over
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