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GERLI & CO. v. COMMISSIONER

Docket No. 4868-72.

73 T.C. 1019 (1980)

GERLI & CO., INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 5, 1980.

Attorney(s) appearing for the Case

Hans A. Nathan, James K. Alford, and Thomas M. Ingoldsby, for the petitioner.

John C. Calhoun, James E. Connor, and Joseph L. Cannella, for the respondent.

STERRETT, Judge:

By letter dated March 28, 1972, respondent determined a deficiency in income taxes due from petitioner Gerli & Co., Inc. (Gerli), and its subsidiaries, for their taxable year ended December 31, 1965, in the amount of $346,448.50. Gerli and its subsidiaries1 had filed as a consolidated group for that taxable year. Gerli is, therefore, for purposes of this case, the sole agent for the consolidated group and is...

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