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COLORADO GAS COMPRESSION, INC. v. C.I.R.

No. 02-9000.

366 F.3d 863 (2004)

COLORADO GAS COMPRESSION, INC., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Tenth Circuit.

April 6, 2004.

Attorney(s) appearing for the Case

Garold Sims of Sims & Boster, Denver, CO, for Petitioner-Appellant.

Teresa T. Milton Attorney, Tax Division, Department of Justice, Washington, D.C. (David English Carmack, Attorney, Tax Division, Department of Justice, Washington, D.C.; Eileen J. O'Connor, Assistant Attorney General, with her on the brief), for Respondent-Appellee.

Before BRISCOE, HOLLOWAY and HARTZ, Circuit Judges.

HOLLOWAY, Circuit Judge.

The IRS determined that petitioner/appellant Colorado Gas Compression, Inc. owed additional taxes totaling over $900,000 for the years 1994, 1995 and 1996. Colorado Gas filed a petition in the United States Tax Court to contest the notice of deficiency in 1998. The parties stipulated to all material facts and submitted the matter to the Tax Court for its decision. The Tax Court rejected the arguments...

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