Sunoco, Inc. and Subsidiaries - Page 3

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                  The parties have stipulated the facts applicable to                 
             the issue considered in this opinion.  During the period                 
             1971 through 1993, petitioner was the common parent of an                
             affiliated group of corporations that included Cordero                   
             Mining Co. or one of its predecessors, Sunedco Coal Co.                  
             and Sunoco Energy Development Co.  When we use the term                  
             “Cordero” in this opinion, we mean Cordero Mining Co.                    
             and its predecessors.  For each of the years in issue,                   
             Cordero was a member of petitioner’s affiliated group of                 
             corporations and was included in the consolidated return                 
             filed by petitioner on behalf of the group.  At the time                 
             the instant petition was filed on its behalf, petitioner’s               
             principal place of business was in Philadelphia,                         
                  Before 1971, Cordero engaged in coal mining in the                  
             Powder River Basin in Wyoming.  In 1971, Cordero acquired a              
             working interest in a Federal lease of 6,560 acres of land               
             near Gillette, Wyoming, that contained approximately 500                 
             million tons of coal reserves.  We sometimes refer to this               
             property as the Gillette mine or the Gillette property.                  

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