Interlake Corporation - Page 19

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          Southern Pac. Co. v. Commissioner, supra.  Accordingly, Acme was             
          not an authorized recipient of the tentative refunds.  We believe            
          that the result we reach today is consistent with, and a logical             
          extension of, the rationale underlying our earlier decisions in              
          Southern Pac. Co. v. Commissioner, supra, and Union Oil Co. v.               
          Commissioner, supra.                                                         
               Consequently, we hold that the tentative refunds are                    
          nonrebate refunds with respect to petitioner and the group for               
          purposes of computing the group's deficiencies for 1981 and 1984.            
          Therefore, respondent cannot seek recovery of the tentative                  
          refunds from petitioner through the deficiency procedures.                   
               We have considered the parties' remaining arguments and find            
          them to be either without merit or unnecessary to reach.                     
               To reflect the foregoing,                                               

                                              An appropriate order                     
                                        will be issued.                                

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