MERRILL LYNCH & CO., & SUBS. v. COMMISSIONER

Docket No. 18170-98.

120 T.C. 12 (2003)

120 T.C. No. 3

MERRILL LYNCH & CO., INC. & SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 15, 2003.


Attorney(s) appearing for the Case

David J. Curtin, Sheri Dillon, Peter J. Genz, William F. Nelson, Kimberly S. Piar and Cornelia J. Schnyder, for petitioner.

Carmen M. Baerga, Jill A. Frisch, Lyle B. Press, and Jody S. Rubinstein, for respondent.


MARVEL, Judge:

Respondent determined the following deficiencies in the Federal income tax of Merrill Lynch & Co., Inc. (Merrill Parent), & Subsidiaries (collectively, the consolidated group or petitioner):

       TYE                                     Deficiency

  Dec. 26, 1986 .............................. $7,704,908
  Dec. 25, 1987 .............................. 12,141,242
  Dec. 30, 1988 ............................

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