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PPL CORP. & SUBS. v. COMMISSIONER

Docket No. 25393-07.

135 T.C. 304 (2010)

PPL CORPORATION & SUBSIDIARIES, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed September 9, 2010.

Attorney(s) appearing for the Case

Richard E. May , Mark B. Bierbower , and Timothy L. Jacobs , for petitioner.

Melissa D. Arndt , Allan E. Lang , Michael C. Prindible , and R. Scott Shieldes , for respondent.

HALPERN, Judge:

PPL Corp. (petitioner) is the common parent of an affiliated group of corporations (the group) making a consolidated return of income. By notice of deficiency, respondent determined a deficiency of $10,196,874 in the group's Federal income tax for its 1997 taxable (calendar) year and also denied a claim for refund of $786,804. The issues for decision are whether respondent properly (1) denied the claim for the refund, which is related to the...

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