OPINION
NIMS, Chief Judge:
This case is before the Court on petitioners' motion for summary judgment under Rule 121. (Rule references are to the Tax Court Rules of Practice and Procedure. Unless otherwise noted, section references are to the Internal Revenue Code of 1954 as amended and in effect for the years at issue.)
Petitioner Ashland Oil, Inc., a domestic corporation with its principal office in Ashland, Kentucky, is the parent company...
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