Jacob Earl Christensen , Attorney, DEPARTMENT OF JUSTICE, Tax Division, Appellate Section, Gilbert Steven Rothenberg , Attorney, DEPARTMENT OF JUSTICE, Office of the Attorney General, Richard Farber , Attorney, DEPARTMENT OF JUSTICE, Civil Division, Immigration Litigation, Washington, DC, for Respondent-Appellee.
Emily Sanford Fisher , Attorney, EDISION ELECTRIC INSTITUTE, Washington, DC, Amicus Curiae for EDISON ELECTRIC INSTITUTE.
Before Manion and Barrett, Circuit Judges, and Gettleman, District Judge.
Gettleman, District Judge.
Petitioner-Appellant Exelon Corporation ("Exelon")1 appeals from a decision of the United States tax court which upheld a determination by the Commissioner of Internal Revenue that Exelon is liable for a deficiency of $431,174,592 for the 1999 tax year and $5,534,611 for the 2001 tax year....
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