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MERRILL LYNCH & CO., INC. v. COMMISSIONER OF INTERNAL REVENUE

No. 18170-98.

131 T.C. No. 19

MERRILL LYNCH & CO., INC. & SUBSIDIARIES, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed December 30, 2008.

Attorney(s) appearing for the Case

Kenneth W. Gideon and Martin D. Ginsburg, for petitioner.

Carmen M. Baerga, Jill A. Frisch, and Lyle Press, for respondent.

SUPPLEMENTAL OPINION

MARVEL, Judge:

This case is before the Court on remand from the Court of Appeals for the Second Circuit. Merrill Lynch & Co. & Subs. v. Commissioner, 386 F.3d 464 (2d Cir. 2004), affg. in part and remanding 120 T.C. 12 (2003). In our prior Opinion, we found that the cross-chain sales of subsidiary stock between brother-sister corporations...

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