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DELAWARE CORP. v. COMMISSIONER

Docket Nos. 2040-02, 2041-02, 2042-02.

88 T.C.M. 589 (2004)

T.C. Memo. 2004-280

Delaware Corp., et al., v. Commissioner.

United States Tax Court.

December 16, 2004.

Attorney(s) appearing for the Case

Harry L. Cohn, for petitioners.

Dustin M. Starbuck, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION1

CHIECHI, Judge:

Respondent determined the following deficiencies in, and accuracy-related penalties under section 6662(a)2 on, each petitioner's Federal income tax (tax):

                                              Accuracy-Related
       Petitioner         Year    Deficiency        Penalty
  Delaware...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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