Legal Opinion

MMC Corp. v. Commissioner

Court of Appeals for the Tenth Circuit

Decided January 13, 2009No. 08-9002PublishedCited by 2 opinions

1Opinion of the Court

TACHA, Circuit Judge.

MMC Inc. and related subsidiaries (“MMC”) 1 did not pay corporate tax on certain income reported in 2000 and 2001. The Commissioner of Internal Revenue assessed a tax deficiency against MMC for $357,534 for tax year 2000 and a deficiency of $468,068 for tax year 2001. The Tax Court upheld the assessments, concluding that income reported in those years as § 481(a) adjustments is taxable built-in gain under 26 U.S.C. § 1374(d)(5). MMC appeals. We have jurisdiction under 26 U.S.C. § 7482(a)(1), and we AFFIRM.

I. BACKGROUND

MMC was incorporated under Kansas law as a subchapter…

2Cases cited4 opinions

Mickey L. Worden Virginia L. Worden v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1993
Colorado Gas Compression, Inc. v. CommissionerCourt of Appeals for the Tenth Circuit · 2004
Argo Sales Co. v. CommissionerUnited States Tax Court · 1995
Rondy, Inc. v. CommissionerUnited States Tax Court · 1995

3Cited by2 opinions

Haddad Motor Group, Inc. v. Karp, Ackerman, Skabowski & Hogan, P.V.Court of Appeals for the First Circuit · 2010
Hacker v. United StatesCourt of Appeals for the Federal Circuit · 2010