Dividend Industries, Inc. v. Commissioner
United States Tax Court
Petitioner is the common parent of an affiliated group of corporations which filed consolidated Federal income tax returns for 1977, 1978, 1979, and 1980. Respondent mailed to petitioner notices of deficiency which determined deficiencies in the 1977 through 1980 Federal income tax liabilities of the affiliated group.
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Petitioner is the common parent of an affiliated group of corporations which filed consolidated Federal income tax returns for 1977, 1978, 1979, and 1980. Respondent mailed to petitioner notices of deficiency which determined deficiencies in the 1977 through 1980 Federal income tax liabilities of the affiliated group. The notices of deficiency, however, made no reference to an affiliated group and did not identify any of petitioner's subsidiary corporations even though the deficiencies are attributable solely to adjustments to income, deduction, and credit items of the subsidiary…
1Opinion of the Court
Dividend Industries, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Dividend Industries, Inc. v. Commissioner
Docket No. 7820-84
United States Tax Court
88 T.C. 145; 1987 U.S. Tax Ct. LEXIS 8; 88 T.C. No. 8;
January 15, 1987. January 15, 1987, Filed
Petitioner is the common parent of an affiliated group of corporations which filed consolidated Federal income tax returns for 1977, 1978, 1979, and 1980. Respondent mailed to petitioner notices of deficiency which determined deficiencies in the 1977 through 1980 Federal income tax liabilities of the affiliated group. The notices of…
2Cases cited7 opinions
- Peninsula Steel Products & Equipment Co. v. CommissionerUnited States Tax Court · 1982
- Anheuser-Busch, Inc. v. CommissionerUnited States Board of Tax Appeals · 1939
- Intervest Enterprises, Inc. v. CommissionerUnited States Tax Court · 1972
- Mississippi River & Bonne Terre Ry. v. CommissionerUnited States Board of Tax Appeals · 1939
- Wobber Bros. v. CommissionerUnited States Board of Tax Appeals · 1934
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