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DEXSIL CORP. v. COMMISSIONER

Docket No. 1349-93.

77 T.C.M. 1973 (1999)

T.C. Memo. 1999-155

Dexsil Corporation v. Commissioner.

United States Tax Court.

Filed May 5, 1999.

Attorney(s) appearing for the Case

William J. Doyle, Charles P. Reed and Mark R. Kravitz, for the petitioner. Robert E. Marum, for the respondent.

SUPPLEMENTAL MEMORANDUM OPINION

COHEN, Chief Judge:

This case is before us on remand from the Court of Appeals for the Second Circuit in Dexsil Corp. v. Commissioner [98-1 USTC ¶ 50,471], 147 F.3d 96 (2d Cir. 1998), vacating and remanding [Dec. 50,552(M)] T.C. Memo. 1995-135. The Court of Appeals directed us:

to make specific findings regarding the following questions...

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