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INTERHOTEL COMPANY, LTD. v. COMMISSIONER

Docket No. 13017-95.

81 T.C.M. 1804 (2001)

T.C. Memo. 2001-151

Interhotel Company, Ltd., Torrey Hotel Enterprises, Inc., Tax Matters Partner, v. Commissioner.

United States Tax Court.

Filed June 22, 2001.

Attorney(s) appearing for the Case

Kenneth W. Gideon, for the petitioner.

Gretchen A. Kindel, for the respondent.

SUPPLEMENTAL MEMORANDUM OPINION

JACOBS, Judge:

This case is before us on remand from the Court of Appeals for the Ninth Circuit. See Interhotel Co., Ltd. v. Commissioner [2000-1 USTC ¶ 50,511], 221 F.3d 1348 (9th Cir. 2000), vacating and remanding without published opinion [Dec. 52,284(M)] T.C. Memo. 1997-449. Torrey Hotel Enterprises, Inc. (THEI), is a California corporation organized and controlled by Douglas...

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