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MARS, INC., AND UNCLE BEN'S, INC. v. COMMISSIONER

Docket No. 39472-85T.

88 T.C. 428 (1987)

MARS, INCORPORATED, AND UNCLE BEN'S, INC., PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 11, 1987.

Attorney(s) appearing for the Case

Don S. Harnack, for the petitioners.

Bernard T. Bress and Cynthia J. Mattson, for the respondent.

OPINION

WILLIAMS, Judge:*

The Commissioner determined that the transformation of a foreign partnership into a foreign corporation was in pursuance of a plan having as one of its principal purposes the avoidance of Federal income tax within the meaning of section 367.1 Pursuant to section 7477, petitioners seek a declaratory judgment of this Court that respondent's determination is not reasonable...

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