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NORFOLK S. CORP. v. COMMISSIONER

Docket Nos. 19305-91, 19306-91.

104 T.C. 417 (1995)

NORFOLK SOUTHERN CORPORATION AND AFFILIATED COMPANIES, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 6, 1995.

Attorney(s) appearing for the Case

Newman T. Halvorson, Jr., Sean F. Foley, Frederick A. Richman, Andrew J. Frackman, Joseph G. Giannola, Richard Alan Brady, and William M. Paul, for petitioners.

Phillip A. Pillar, John A. Guarnieri, Stephen M. Miller, and Keith L. Gorman, for respondent.

SUPPLEMENTAL OPINION

PARR, Judge:

The Court's opinion in these cases, 104 T.C. 13 (1995), was issued on January 11, 1995 (prior opinion). Thereafter, on February 13, 1995, pursuant to Rule 161,1 respondent filed a motion for reconsideration of opinion. The Court directed petitioners to file a response to respondent's motion. On March 6, 1995, petitioners filed their objection to respondent...

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