- 19 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19
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