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SOUTHERN PACIFIC TRANSPORTATION CO. v. COMMISSIONER

Docket No. 3493-69.

75 T.C. 497 (1980)

SOUTHERN PACIFIC TRANSPORTATION COMPANY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 31, 1980.

Attorney(s) appearing for the Case

Arnold I. Weber and Alan S. Beinhorn, for the petitioner.

James Booher, Vernon R. Balmes, Lawrence G. Becker, Eugene H. Ciranni, Randall G. Dick, Thomas F. Kelly, William E. Saul, and Nicholas G. Stucky, for the respondent.

DRENNEN, Judge:

In the statutory notice in this case, respondent determined income tax deficiencies as follows:

   TYE Dec. 31—               Deficiency

           1959 ..................   $4,411,069.04
           1960 ..................    5,986,337.91
           1961 ..................    9,994,970.22

In its petition, petitioner placed all of the asserted deficiencies in controversy. Petitioner also alleged...

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