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PDV America, Inc. v. Commissioner

Docket Nos. 12124-02, 12125-02.

87 T.C.M. 1330 (2004)

T.C. Memo. 2004-118

PDV America, Inc. and Subsidiaries v. Commissioner. PDV Holding, Inc. and Subsidiaries v. Commissioner.

United States Tax Court.

May 12, 2004.

Attorney(s) appearing for the Case

Lisa M. Cipriano, Michael A. Clark, and Kevin R. Pryor, for petitioners.

C. Glenn McLoughlin, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

MARVEL, Judge:

Respondent determined deficiencies with respect to petitioners' income tax as follows:

Docket No. 12124-02

         Year       Deficiency

         1996       $119,774

Docket No. 12125-02

         Year       Deficiency

         1997       $218,170

Petitioners timely filed petitions contesting respondent...

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