Interlake Corporation - Page 8

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          application package was a copy of petitioner's Form 1120X,                   
          Amended U.S. Corporation Income Tax Return, for the taxable year             
          1984.2  That Form 1120X indicates that petitioner is the                     
          "Successor in interest to Interlake, Inc. [i.e., Acme] and                   
          Consolidated Subsidiaries."                                                  
               On the second Form 1139, Acme and its consolidated                      
          subsidiary requested a tentative refund of income tax in the                 
          amount of $148,692 attributable to the carryback of $174,931 of              
          investment tax credits and certain credits for increasing                    
          research activity from Acme's (i.e., the group's) 1984 tax year              
          to Acme's (i.e., the group's) 1981 tax year.3                                
               After reviewing the two Forms 1139 filed by Acme and its                
          consolidated subsidiary, the service center advised Acme that it             
          could not process the first Form 1139 (relating to 1984 and 1985)            
          as filed because it did not take into account the tentative                  
          refund allowance previously made to petitioner and the group with            
          respect to Acme's (i.e., the group's) 1984 tax year.  Acme then              
          filed, on or about October 26, 1987, a revised Form 1139 for tax             

          2    Petitioner filed the Form 1120X on or about Oct. 31, 1986,              
          subsequent to the restructuring transaction and spinoff, to                  
          eliminate $2,120,691 of investment tax credit (ITC) carryovers               
          from 1982 and 1983.  As a result of an Internal Revenue Service              
          audit, the group's tax liability for 1980 and 1981 was                       
          sufficiently increased to absorb the 1982 and 1983 ITC's as                  
          3    Acme also filed Form 8302, Application for Electronic Funds             
          Transfer of Tax Refund of $1 Million or More, in which it                    
          requested that the tentative refunds for 1984 and 1985 be wired              
          to an account maintained by Acme at the First Natl. Bank of                  

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