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IN RE HILLSBOROUGH HOLDINGS CORP.

Bankruptcy Nos. 89-9715-8P1, to 89-9746-8P1, 90-11997-9P1, Adversary No. 91-313.

295 B.R. 679 (2003)

In re HILLSBOROUGH HOLDINGS CORPORATION, et al., Debtors. Hillsborough Holdings Corporation, et al., Plaintiffs, v. United States of America, Defendant.

United States Bankruptcy Court, M.D. Florida, Tampa Division.

March 20, 2003.

Attorney(s) appearing for the Case

Stephen D. Gardner, New York City, James D. O'Donnell and Renee D. Grosse, Jacksonville, FL, Don M. Stichter, Tampa, FL, for Plaintiffs.

Robert L. Welsh, Trial Attorney, Tax Division, U.S. Department of Justice, Washington, DC, for Defendant.

FINDINGS OF FACT, CONCLUSIONS OF LAW AND MEMORANDUM OPINION (ISSUE 35 FOR THE TAX YEARS 1992 THROUGH 1994)

ALEXANDER L. PASKAY, Chief Judge.

These are the confirmed Chapter 11 cases of Hillsborough Holding Corporation and its thirty-two wholly owned subsidiaries (Debtors) and the matter under consideration is a claim set forth in Count VII of the Amended Complaint entitled "Amended Complaint for Determination of Tax Liability and for Determination...

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