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PHILLIPS PETROLEUM CO. v. COMMISSIONER

Docket No. 34019-87.

92 T.C. 885 (1989)

PHILLIPS PETROLEUM CO. AND AFFILIATED SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 4, 1989.

Attorney(s) appearing for the Case

Stephen D. Gardner and Ann E. Purintun, for the petitioner.

Val J. Albright, for the respondent.

OPINION

SCOTT, Judge:

This case was heard by Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7443A of the Code.1 The Court agrees with and adopts the Special Trial Judge's opinion, which is set forth below.

OPINION OF THE SPECIAL TRIAL JUDGE

PANUTHOS, Special Trial Judge:

This case came before the Court on respondent...

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