T.C. Memo. 1999-155
UNITED STATES TAX COURT
DEXSIL CORPORATION, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1349-93. Filed May 5, 1999.
William J. Doyle, Charles P. Reed, and Mark R. Kravitz,
for petitioner.
Robert E. Marum, for respondent.
SUPPLEMENTAL MEMORANDUM OPINION
COHEN, Chief Judge: This case is before us on remand from
the Court of Appeals for the Second Circuit in Dexsil Corp. v.
Commissioner, 147 F.3d 96 (2d Cir. 1998), vacating and remanding
T.C. Memo. 1995-135. The Court of Appeals directed us:
to make specific findings regarding the following
questions: (1) whether a hypothetical investor would
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