Memorandum Findings of Fact and Opinion
PARKER, Judge:
Respondent determined a deficiency in petitioners' Federal income tax in the amount of $2,516,103 for the section 338 deemed sale return for an acquisition that occurred on October 27, 1986.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the relevant years before the Court, and all Rule references are to the Tax Court Rules of Practice and Procedure...
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