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THRIFTY OIL CO. & SUBS. v. COMMISSIONER

Docket No. 1376-10.

139 T.C. 198 (2012)

THRIFTY OIL CO. & SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 30, 2012.

Attorney(s) appearing for the Case

Gary S. Colton, Jr. , Daniel A. Dumezich , and Richard E. Kurkowski , for petitioner.

Kevin G. Croke , Davis G. Yee , and Matthew A. Williams , for respondent.

OPINION

WHERRY, Judge:

This case is before the Court on a petition for redetermination of income tax deficiencies determined by respondent for petitioner's taxable years ended (TYE) September 30, 2000, 2001, and 2002. In its simplest form, the issue is whether, given Charles Ilfeld Co. v. Hernandez, 292 U.S. 62 (1934), and its progeny, petitioner is entitled to environmental remediation expense deductions claimed...

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