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cannot identify any error committed by respondent in paying the
tentative carryback adjustments and later determining
deficiencies with respect to them, much less a clerical or
computer error. See Pesch v. Commissioner, 78 T.C. at 115.
Petitioner repeats ad nauseam that it was an unauthorized
recipient of the tentative refunds because it was the former
common parent of the affiliated group. However, the record
indicates respondent treated petitioner as the common parent of
the affiliated group for 10 years following the payment of the
tentative refunds. In fact, respondent’s current concession on
this score in the stipulations of settled issues he signed with
Interlake and petitioner is a stipulation of a legal conclusion
that, had we been called upon to consider it, we would ignore.
See Rose Ann Coates Trust v. Commissioner, 55 T.C. 501, 511
(1970) (stipulation of legal conclusions may be disregarded),
affd. 480 F.2d 468 (9th Cir. 1973). Section 1.1502-75(d)(1),
Income Tax Regs., provides the general rule that a group shall
continue if the common parent remains as the common parent and at
least one subsidiary remains affiliated with it, whether or not
the subsidiary was a member of the group in a prior year, and
whether or not one or more corporations have ceased to be
subsidiaries at any time after the group was formed. Since
petitioner was the common parent of an affiliated group that
consisted of petitioner and AMC, petitioner’s group represents
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