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GUY F. ATKINSON CO. OF CAL. v. C.I.R.

No. 85-7715.

814 F.2d 1388 (1987)

GUY F. ATKINSON COMPANY OF CALIFORNIA AND SUBSIDIARIES, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided April 15, 1987.

As Amended June 25, 1987.

Attorney(s) appearing for the Case

C. Douglas Floyd, San Francisco, Cal., for petitioners-appellants.

William A. Whitledge, Washington, D.C., for respondent-appellee.

Before KENNEDY, TANG and THOMPSON, Circuit Judges.

TANG, Circuit Judge:

Guy F. Atkinson Co. ["Atkinson"] appeals from a determination by the United States Tax Court of a $4,115,981 tax deficiency. We have jurisdiction under 26 U.S.C. § 7482. We affirm.

FACTS AND PROCEEDINGS:

Atkinson's subsidiary, Walsh Construction Co., was managing partner in a joint venture, Water Tunnel Contractors ["WTC"]1. WTC was organized...

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