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RESEARCH CORP. v. COMMISSIONER

Docket No. 9458-10.

138 T.C. 192 (2012)

RESEARCH CORPORATION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed February 29, 2012.

Attorney(s) appearing for the Case

John Frederick Daniels, III , for petitioner.

Annie Lee and Peter James Gavagan , for respondent.

OPINION

HAINES, Judge:

Respondent determined a deficiency of $879,468 in petitioner's Federal excise tax for 2003. The issues for decision after concessions are: (1) whether petitioner is liable for excise tax under section 49801 for 2003 on a reversion received from an employee pension plan, and (2) if we find that petitioner is not liable for excise tax under section 4980, whether petitioner is entitled to an overpayment...

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