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ACC's acquired acquisition activities additional agree agreement Alcon P.R. allocation amount annuity Appeals applicable argues assets Avitene Bank bankruptcy benefits burden capital claim Code Commissioner Congress connection construction contracts corporation costs Court decision deduction deficiency deposits determination effect election employees escrow expenditures expenses fact failed Federal fees filed follows Form Fund gross income hearing held hold income tax incurred individual insolvent installment interest Internal Revenue Internal Revenue Code issue Judge liability limited loans loss majority manufacturing meaning MedChem P.R. ment notice Office operation opinion paid parties partnership payment percent period petition petitioner's petitioners provides purchase pursuant reasonable received references regard regulations relief reported respect respondent respondent's result Rule supra Tax Regs tax return taxable taxpayer term tion trade or business transaction transferred United