Trinova Corporation and Subsidiaries - Page 3

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          Background                                                                  
               This case was submitted fully stipulated under Rule 122.               
          The stipulation of facts and the accompanying exhibits are                  
          incorporated herein by this reference and found accordingly.                
               Petitioner, an accrual basis taxpayer, had its principal               
          offices in Maumee, Ohio, at the time it filed its petition                  
          herein.  Petitioner changed its name to Trinova from the Libbey-            
          Owens-Ford Company (LOF) on July 31, 1986.  Petitioner timely               
          filed a consolidated Federal income tax return with certain of              
          its subsidiaries for the years at issue with the Internal Revenue           
          Service Center, Cincinnati, Ohio, or the Internal Revenue Service           
          office in Toledo, Ohio.  Petitioner was engaged in the fluid                
          power and plastics businesses, and in the manufacture of glass.             
          The glass business was referred to as the "LOF Glass Division".             
               One of LOF's largest shareholders was Pilkington Brothers              
          (Pilkington), an English company, which owned 29 percent of                 
          petitioner's common stock through its wholly owned U.S.                     
          subsidiary, Pilkington Holdings, Inc. (Pilkington Holdings).  Two           
          of petitioner's fourteen directors were associated with                     
          Pilkington.  In late 1985, Pilkington approached LOF and began              
          negotiations concerning the possibility of acquiring the glass              
          business.                                                                   


          2(...continued)                                                             
          between subpart F income and non-subpart F income, will be                  
          decided later by a separate opinion.                                        




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