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Lines, Inc. v. Commissioner, T.C. Memo. 1965-71, affd. 354
F.2d 830 (8th Cir. 1965).
On the basis of the above, we find that, under Florida
law, petitioner continues in existence, notwithstanding its
administrative dissolution, during the time necessary to
seek redetermination of the instant notice of deficiency in
this Court and to wind up its other business affairs. We
further find that petitioner has the legal capacity under
Florida law to file the subject petition for
redetermination and to litigate in this Court, even though
petitioner had been administratively dissolved at the time
the petition was filed. See Rule 60(c); Starvest U.S.,
Inc. v. Commissioner, supra; cf. Bloomington Transmission
Servs., Inc. v. Commissioner, 87 T.C. 586 (1986); Bared &
Cobo Co. v. Commissioner, 77 T.C. 1194 (1981); Padre Island
Thunderbird, Inc. v. Commissioner, 72 T.C. 391 (1979);
Great Falls Bonding Agency, Inc. v. Commissioner, 63 T.C.
304 (1974); Lee Enters., Inc. v. Commissioner, T.C. Memo.
1992-629; Am. Police & Fire Found., Inc. v. Commissioner,
T.C. Memo. 1981-704. Respondent does not seem to disagree
with these findings. As mentioned above, respondent
concedes that “petitioner is entitled to bring this
action”. We take this statement as respondent’s concession
that petitioner has the capacity under Rule 60(c) and the
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