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SOROS ASSOCIATES INTERNATIONAL, INC. v. COMMISSIONER

Docket No. 2750-80.

43 T.C.M. 566 (1982)

T.C. Memo. 1982-79

Soros Associates International, Inc. v. Commissioner.

United States Tax Court.

Filed February 16, 1982.

Attorney(s) appearing for the Case

David W. Welles, 375 Park Ave., New York, N.Y., for the petitioner. William M. Gross, for the respondent.

Memorandum Opinion

FAY, Judge:

This case is before us on petitioner's "Motion for Ruling on Burden of Proof with Respect to Retention of Earnings." The issue presented is whether petitioner's statement, submitted pursuant to section 534(c),1 is sufficient to shift the burden of proof to respondent with respect to the grounds for accumulation set forth in that statement.

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