Sundstrand Corp. v. Commissioner
United States Tax Court
For many years, P and some of its subsidiaries, including Sundstrand Data Control, Inc. (SDC), have served as prime contractors or subcontractors on various defense contracts.
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For many years, P and some of its subsidiaries, including Sundstrand Data Control, Inc. (SDC), have served as prime contractors or subcontractors on various defense contracts. These defense contracts are subject to certain regulatory requirements, including the Cost Accounting Standards (CAS), the Truth-in-Negotiations Act (TINA), the Federal Acquisition Regulations (FAR), and/or the Defense Acquisition Regulations (DAR). In 1988, following grand jury investigations, P and SDC entered guilty pleas to bills of information charging various criminal activities associated with some of these…
1Opinion of the Court
OPINION
Hamblen, Judge:
Respondent determined the following deficiencies in petitioners' income taxes for 1979, 1980, 1981, and 1982 (hereinafter sometimes referred to collectively as. the years in suit):
Year Amount of deficiency
1979 . $13,674,981
1980 . 28,541,936
1981 . 27,099,275
1982 . 18,461,344
Respondent also determined that petitioners are liable for increased interest under section 6621(c), formerly section 6621(d), on the basis that the deficiencies attributable to the section 482 issue also at issue in these cases constituted substantial underpayments attributable to tax-motivated…
2Cases cited19 opinions
- Anderson v. Liberty Lobby, Inc.Supreme Court of the United States · 1986
- Celotex Corp. v. Catrett, Administratrix of the Estate of CatrettSupreme Court of the United States · 1986
- Reiter v. Sonotone Corp.Supreme Court of the United States · 1979
- Naftel v. CommissionerUnited States Tax Court · 1985
- Lichter v. United StatesSupreme Court of the United States · 1948
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- Roberts v. Comm'rUnited States Tax Court · 2002
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