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DEERE & CO. & CONSOL. SUBS. v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 20320-06.

133 T.C. 246 (2009)

DEERE & COMPANY AND CONSOLIDATED SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed October 22, 2009.

Attorney(s) appearing for the Case

Laurence M. Bambino, Michael B. Shulman, Richard John Gagnon, Jr., and Douglas R. McFadyen, for petitioner.

Reid Michael Huey, for respondent.

OPINION

CHIECHI, Judge:

This case is before us on the motion for summary judgment of respondent (respondent's motion) and the motion for summary judgment of Deere & Co. and Consolidated Subsidiaries (petitioner's motion).1 We shall grant respondent's motion, and we shall deny petitioner's motion.

Background

At the time of the filing of the petition, petitioner maintained its principal office...

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