Legal Opinion

Davis Bros. Restaurant, Inc. v. Commissioner

United States Tax Court

Decided July 2, 1973No. Docket Nos. 6484-71, 6486-71, 6487-71, 6488-71, 6489-71, 6490-71, 6491-71, 6492-71, 6493-71, 6494-71, 6495-71Published

For several years prior to their fiscal year 1967, petitioners, members of a controlled group of corporations, had filed their income tax returns and computed their tax with the benefit of the multiple surtax exemptions authorized by sec. 1562, I.R.C. 1954. For the fiscal year 1967, two of the corporations, members of an affiliated group as defined in sec. 1504, I.R.C. 1954, filed a single return, combining their income, deductions, and credits, and otherwise (except in…

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For several years prior to their fiscal year 1967, petitioners, members of a controlled group of corporations, had filed their income tax returns and computed their tax with the benefit of the multiple surtax exemptions authorized by sec. 1562, I.R.C. 1954. For the fiscal year 1967, two of the corporations, members of an affiliated group as defined in sec. 1504, I.R.C. 1954, filed a single return, combining their income, deductions, and credits, and otherwise (except in certain specific respects) complying with the regulations on the filing of consolidated returns. Other members of the…

1Opinion of the Court

Davis Bros. Restaurant, Inc., et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent

Davis Bros. Restaurant, Inc. v. Commissioner

Docket Nos. 6484-71, 6486-71, 6487-71, 6488-71, 6489-71, 6490-71, 6491-71, 6492-71, 6493-71, 6494-71, 6495-71

United States Tax Court

60 T.C. 525; 1973 U.S. Tax Ct. LEXIS 96; 60 T.C. No. 58;

July 2, 1973, Filed

Decisions will be entered under Rule 50 in docket Nos. 6484-71, 6487-71, and 6490-71.

Decisions will be entered for the respondent in docket Nos. 6486-71, 6488-71, 6489-71, 6491-71, 6492-71, 6493-71, 6494-71, and 6495-71.

For several years prior to…

2Cases cited9 opinions

  1. Regal, Inc. v. CommissionerUnited States Tax Court · 1969
  2. Regal, Incorporated v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1970
  3. Patten Fine Papers, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1957
  4. American Trans-Ocean Navigation Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1956
  5. Landy Towel & Linen Service, Inc. v. CommissionerUnited States Tax Court · 1962

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