OAKES, Circuit Judge:
Appellant taxpayer is the successor to a family of foreign car corporations, consisting of a parent, Hoffman Motor Car Co., Inc. (hereinafter "Hoffman Motor") and several wholly owned subsidiaries—Hoffman-Porsche Corp. (hereinafter "Hoffman-Porsche"); Hoffman Motors Eastern Division, Inc. (hereinafter "Eastern"); and Hoffman of California, Inc., a/k/a Hoffman Western Division, Inc. (hereinafter "Western"). The appeal relates to automobile...
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