OPINION
COHEN, Judge:
Respondent determined deficiencies in petitioner's consolidated Federal income tax for 1986, 1987, and 1988 in the amounts of $1,356,802, $1,321,896, and $7,099,160, respectively.
After concessions by the parties, the issues for decision are: (1) Whether one of petitioner's subsidiaries is entitled to compute its tax liability for 1987 and 1988 pursuant to section 1341 and (2) whether funds overcollected pursuant to fuel...
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