BENTON, Circuit Judge.
The tax court ruled, on summary judgment, that Nestlé Purina Petcare Company—hereafter Ralston, its name during the relevant years—could not deduct payments for cash distribution redemptive dividends. Ralston Purina Co. v. Comm'r, 131 T.C. 29, 2008 WL 4159698 (2008). Ralston appeals. Having jurisdiction under 26 U.S.C. § 7482, this court affirms.
I.
In 1989, Ralston established an employee stock...
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