J & S Carburetor Co. v. Commissioner
United States Tax Court
Subsidiaries in an affiliated group of corporations filing a consolidated return petitioned this Court while the common parent corporation was in bankruptcy. Respondent moved to dismiss for lack of jurisdiction. Held, sec. 1.1502-77(a), Income Tax Regs., precludes the subsidiaries from petitioning this Court; accordingly, respondent's motion to dismiss for lack of jurisdiction is granted.
1Opinion of the Court
J & S Carburetor Company, Redfish Bay Terminal, Inc., BQP Industries, Inc., Southland Technology, Inc., Synfuel Systems, Inc., and Synfuel Industries, Inc., Petitioners v. Commissioner of Internal Revenue, Respondent
J & S Carburetor Co. v. Commissioner
Docket No. 41003-85
United States Tax Court
93 T.C. 166; 1989 U.S. Tax Ct. LEXIS 113; 93 T.C. No. 17;
August 3, 1989August 3, 1989, Filed
An appropriate order granting respondent's motion to dismiss will be entered.
Subsidiaries in an affiliated group of corporations filing a consolidated return petitioned this Court while the common parent…
2Cases cited4 opinions
- McClamma v. CommissionerUnited States Tax Court · 1981
- Baron v. CommissionerUnited States Tax Court · 1979
- Southern Pacific Co. v. CommissionerUnited States Tax Court · 1985
- J & S Carburetor Co. v. CommissionerUnited States Tax Court · 1989