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(1) Whether a deemed section 304 redemption in the form of
a 1986 cross-chain stock sale between brother-sister corporations
in a consolidated group must be integrated with the later sale of
the cross-chain seller outside the consolidated group and treated
as a redemption in complete termination under section 302(a) and
(b)(3) as respondent contends, or whether the deemed section 304
redemption qualified as a distribution of property taxable as a
dividend under section 301 as petitioner contends; and
(2) whether deemed section 304 redemptions in the form of
eight 1987 cross-chain stock sales between brother-sister
corporations in a consolidated group must be integrated with the
later sale of the cross-chain seller outside the consolidated
group and treated as a redemption in complete termination under
section 302(a) and (b)(3) as respondent contends, or whether the
deemed section 304 redemptions were distributions of property
taxable as dividends under section 301 as petitioner contends.
FINDINGS OF FACT
Some of the facts have been stipulated. We incorporate the
stipulated facts into our findings by this reference.
Merrill Parent is a corporation organized under Delaware law
and is the parent corporation of an affiliated group of
corporations that filed consolidated Federal income tax returns
4(...continued)
Commissioner, 92 T.C. 661, 683 (1989); Money v. Commissioner, 89
T.C. 46, 48 (1987).
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