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CERAND & COMPANY, INC. v. COMMISSIONER

Docket No. 2767-97.

82 T.C.M. 755 (2001)

T.C. Memo. 2001-271

Cerand & Company, Inc. v. Commissioner.

United States Tax Court.

Filed October 9, 2001.

Attorney(s) appearing for the Case

Gerard A. Cerand, [an officer], Washington, D.C., for the petitioner. Gregory S. Matson and Warren P. Simonsen, for the respondent.

SUPPLEMENTAL MEMORANDUM FINDINGS OF FACT AND OPINION

GERBER, Judge:

This case was remanded for further proceedings by the Court of Appeals for the District of Columbia Circuit. Cerand & Co. v. Commissioner, 254 F.3d 258 (D.C. Cir. 2001) (Cerand II). In [Dec. 52,972(M)] T.C. Memo. 1998-423 (Cerand I), we held that the advances petitioner made to sister corporations were equity...

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