Home Group v. Commissioner
United States Tax Court
P, in the process of appealing from a decision of this Court, filed an appeal bond for purposes of staying assessment and collection of P's affiliated and consolidated group's redetermined tax deficiency.
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P, in the process of appealing from a decision of this Court, filed an appeal bond for purposes of staying assessment and collection of P's affiliated and consolidated group's redetermined tax deficiency. Sec. 7485(a), I.R.C. 1986. The bond was issued by S, which is otherwise properly authorized as a surety under 31 U.S.C. sec. 9304 (1982). S is also a subsidiary of P and a member of the affiliated group that filed consolidated returns and, as such, is responsible for any finally determined tax deficiency. R objects to the use of S's bond on the ground that it does not represent adequate…
1Opinion of the Court
The Home Group, Inc., as Agent Under the Provisions of Treasury Regulation Section 1.1502-77(d) for City Investing Co. and the Consolidated Group of Which City Investing Com. Was the Common Parent, Petitioner v. Commissioner of Internal Revenue, Respondent
Home Group v. Commissioner
Docket No. 17739-82
United States Tax Court
92 T.C. 940; 1989 U.S. Tax Ct. LEXIS 65; 92 T.C. No. 59;
May 10, 1989. May 10, 1989, Filed
P, in the process of appealing from a decision of this Court, filed an appeal bond for purposes of staying assessment and collection of P's affiliated and consolidated group's…
2Cases cited21 opinions
- National Union of Marine Cooks & Stewards v. ArnoldSupreme Court of the United States · 1954
- In the Matter of Yale Express System, Inc., Debtor. Boston Insurance Company v. F. Ralph Nogg, TrusteeCourt of Appeals for the Second Circuit · 1966
- Redding & Company, Inc. v. Russwine Construction CorporationCourt of Appeals for the D.C. Circuit · 1969
- Home Group v. CommissionerUnited States Tax Court · 1988
- Concord Casualty & Surety Co. v. United StatesCourt of Appeals for the Second Circuit · 1934
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