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UTILICORP UNITED, INC. v. COMMISSIONER

Docket No. 8563-94.

73 T.C.M. 1835 (1997)

T.C. Memo. 1997-47

Utilicorp United, Inc. & Subsidiaries, f.k.a. Missouri Public Service Co. v. Commissioner.

United States Tax Court.

Filed January 27, 1997.

Attorney(s) appearing for the Case

James G. Kreissman, Michael H. Simonson, and Naftali Z. Dembitzer, New York, N.Y., for the petitioner. Peter J. Graziano and Pamela L. Cohen, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

HALPERN, Judge:

Petitioner Utilicorp United, Inc. (petitioner) is the common parent corporation of an affiliated group of corporations making a consolidated return of income (the affiliated group). Respondent has determined deficiencies of $2,462,443 and $229,479 in the consolidated Federal taxable income of the affiliated group for the group's 1984 and 1987 taxable (calendar) years, respectively. The only issue remaining...

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