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2UBC 3UBC 9th Cir affd affg agreement Alhambra property allocated amended annuity contract apply assets Atrium bad debt portion Bank basis carryback claim Code Commis Commissioner computing consolidated return Consolidated's customer core amount core supplier Corp cost Court of Appeals customer cores declaratory judgment deduction deficiency determined docket employee estate tax exchange fair market value filed Fluor Corp Income Tax Regs income tax return interested party Internal Revenue Internal Revenue Code Internal Revenue Service issue Jaussaud Enterprises LIFO inventory method limitations MEBA Plan ment partnership payment period peti petitioner petitioner's provides purchase purposes pursuant raw materials remanufactured automobile reported respect respondent respondent's rule salvage yard second lease section 471 settlement sioner Stat statute statute of limitations Subs Summerlin supra T.C. Memo Tax Court tax liability taxpayer tion Tracinda transfer UBC affiliated group underpayment United United Bank Center Wehr