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GENERAL MOTORS CORP. & SUBS. v. COMMISSIONER

Docket No. 27026-96.

112 T.C. 270 (1999)

GENERAL MOTORS CORPORATION & SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 25, 1999.

Attorney(s) appearing for the Case

Raymond P. Wexler, Todd F. Maynes, and William R. Welke, for petitioner.

Nancy B. Herbert and John A. Guarnieri, for respondent.

OPINION

VASQUEZ, Judge:

Respondent determined a deficiency of $339,076,705 in petitioner's 1985 consolidated Federal income tax. The issues in this case, the rate support and the special tools issues, have been bifurcated for separate resolution. This opinion addresses the rate support issues.

After concessions by the parties,1 the issues for decision are: (1) Whether General Motors Corp. (GM) and its consolidated...

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