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PECO FOODS, INC. & SUBSIDIARIES v. COMMISSIONER OF INTERNAL REVENUE

No.13789-08.

T.C. Memo. 2012-18

PECO FOODS, INC. & SUBSIDIARIES, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed January 17, 2012.

Attorney(s) appearing for the Case

James H. Williams, III and John S. Rice , for petitioner.

William B. McClendon and Francis C. Mucciolo , for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

LARO, Judge.

Peco Foods, Inc. (Peco), is an Alabama corporation and the parent company of an affiliated group of corporations that file their Federal income tax returns on a consolidated basis.1 Peco petitioned the Court to redetermine respondent's determination of Federal income tax deficiencies of $120,751, $678,978, and $727,323 for its taxable years ended March 28, 1998 (1997 taxable...

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