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GENERAL SIGNAL CORP. & SUBSIDIARIES v. COMMISSIONER

Docket No. 20064-92.

103 T.C. 216 (1994)

GENERAL SIGNAL CORPORATION AND SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 22, 1994.

Attorney(s) appearing for the Case

Russell E. Greenblatt, Rex A. Guest, and David K. Schmitt, for petitioner.

Victoria Wilson Fernandez, Randall P. Andreozzi, Andrew W. Stumpff, and Michael Roach, for respondent.

NIMS, Judge:

Respondent determined deficiencies in Federal income tax with respect to petitioner's 1986 and 1987 taxable years in the amounts of $15,388,891 and $6,787,120, respectively.

Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.

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