Interlake Corporation - Page 6

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          Additionally, neither petitioner nor Acme owns any shares of                 
          stock in the other or any of the other's affiliates.                         
               The parties do not stipulate as to the tax character of the             
          restructuring transaction or the spinoff.                                    
          The Tentative Refund Allowances                                              
               On their 1986 consolidated Federal income tax return, filed             
          on or about August 7, 1987, petitioner and the group reported a              
          consolidated net operating loss (CNOL) in the amount of                      
          $8,461,369 and excess consolidated general business credits in               
          the amount of $1,496,693.  The return was prepared on the basis              
          that petitioner is the successor common parent of the group, and             
          it included the taxable income or loss of petitioner and each                
          member of the group for either (1) the entire 52-53 week year                
          (beginning on December 30, 1985, and ending on December 28, 1986)            
          or (2) the portion of that taxable year during which each such               
          corporation was a member of the group.                                       
               On or about August 11, 1987, petitioner and the group filed,            
          with the Internal Revenue Service Center, Kansas City, Missouri              
          (service center), Form 1139, Corporation Application for                     
          Tentative Refund.  On the application, petitioner and the group              
          requested a tentative refund of income tax in the amount of                  
          $5,346,097 attributable to the carryback of the 1986 CNOL and                
          excess consolidated business credits to the group's 1984 taxable             
          year.  Petitioner attached to the application for tentative                  
          refund allowance a statement detailing the restructuring                     

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