Uniband, Inc. v. Commissioner

140 T.C. No. 13

UNITED STATES TAX COURT UNIBAND, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 4718-06. Filed May 22, 2013. P is a Delaware corporation, wholly owned by T, an Indian tribe. For the years at issue P attempted to file consolidated returns with C, another corporation wholly owned by T. P contends that T is the common parent corporation of P and C and that together they constitute an affiliated group eligible to file a consolidated return. On the returns filed, P did not claim Indian employment credits under I.R.C. sec. 45A even though P was entitled…