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EXELON CORP. v. COMMISSIONER

Docket Nos. 29183-13, 29184-13.

147 T.C. 230 (2016)

147 T.C.No. 9

EXELON CORPORATION, AS SUCCESSOR BY MERGER TO UNICOM CORPORATION AND SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. EXELON CORPORATION AND SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 19, 2016.

Attorney(s) appearing for the Case

David F. Abbott , Joel V. Williamson , Erin G. Gladney , Kristin M. Mikolaitis , Andrew W. Steigleder , Michelle A. Spiegel , and Michael D. Educate , for petitioner.1

Matthew I. Root , Elizabeth P. Flores , Steven N. Balahtsis , Abigail F. Dunnigan , Lisa M. Goldberg , Casey R. Kroma , and Michael T. Shelton , for respondent.

These cases are consolidated for purposes of trial, briefing, and opinion. Respondent determined the following deficiencies and penalties in petitioner's2 Federal income tax in timely issued notices of deficiency:

                            Penalty
Year      Deficiency...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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