Canal Corp. v. Comm'r, 2010 U.S. Tax Ct. LEXIS 25 (T.C. Aug. 5, 2010)

The Service determined a $183,458,981 deficiency in the Chesapeake Corporation's Federal income tax, asserting that Chesapeake owed a $36,691,796 substantial understatement of income tax penalty under section 6662(a) for 1999. Chesapeake's subsidiary's contributed its assets and most of its...