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STANDARD OFFICE BLDG. CORP. v. U.S.

Nos. 86-2460, 86-2906.

819 F.2d 1371 (1987)

STANDARD OFFICE BUILDING CORPORATION and Santa Fe Land Improvement Company, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided May 19, 1987.

Attorney(s) appearing for the Case

Brian J. McKenna, Santa Fe Southern Pacific Corp., Chicago, Ill., for plaintiffs-appellants.

Nancy G. Morgan, Chief Appellate Sec., Tax Div., Dept. of Justice, David I. Pincus, Washington, D.C., for defendant-appellee.

Before BAUER, Chief Judge, and POSNER and EASTERBROOK, Circuit Judges.

POSNER, Circuit Judge.

These consolidated appeals by two affiliates of the Atchison, Topeka and Santa Fe Railway — Standard Office Building Corporation and Santa Fe Land Improvement Company — present two difficult questions: one under the Railroad Retirement Tax Act, 26 U.S.C. §§ 3201 et seq.; the other under the Internal Revenue Code's three-year statute of limitations on the assessment of...

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