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SOUTHERN PACIFIC TRANSPORTATION CO. v. COMMISSIONER

Docket No. 7501-72.

84 T.C. 367 (1985)

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

United States Tax Court.

Filed March 12, 1985.

Attorney(s) appearing for the Case

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

Peter D. Bakutes, James Booher, Vernon R. Balmes, Bernard Plamer, Lawrence G. Becker, and Randall G. Dick, for the respondent.

OPINION

Background

JACOBS, Judge:*

Petitioner herein is Southern Pacific Transportation Co. ("Transportation"), in its capacity as transferee of the assets of Southern Pacific Co. ("former Southern Pacific"), the common parent of an affiliated group of corporations.1 This case is before the Court on Transportation's

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