Century Data Sys. ex rel. California Computer Prods. v. Commissioner
United States Tax Court
P at all times relevant herein maintained and closed its books on the basis of a calendar year annual accounting period. P timely filed a separate return on a calendar basis for 1968 and 1969. For 1970, P timely filed a short period separate return for the 6-month period ending June 30, 1970. P then joined in the filing of consolidated returns of a group of related corporations.
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P at all times relevant herein maintained and closed its books on the basis of a calendar year annual accounting period. P timely filed a separate return on a calendar basis for 1968 and 1969. For 1970, P timely filed a short period separate return for the 6-month period ending June 30, 1970. P then joined in the filing of consolidated returns of a group of related corporations. The returns were filed on the basis of fiscal years ended June 30, 1971, and June 30, 1972. R determined P was not an affiliated member and, thus, was not entitled to join in such consolidated returns. R originally…
1Opinion of the Court
OPINION
NlMS, Judge:
This matter is before the Court on petitioner’s motion for judgment on the pleadings pursuant to Rule 120.1 Respondent has submitted, and we have accepted, matters outside the pleadings. We therefore treat petitioner’s motion as one for summary judgment pursuant to Rule 121.2
Respondent determined deficiencies in petitioner’s Federal income tax as follows:
Year ended Deficiency
Dec. 31, 1970. $3,291,164.56
Dec. 31, 1971. 3,717,512.59
Apr. 3, 1972. 299,377.80
The sole issue remaining before the Court is whether petitioner is estopped from raising the statute of limitations as a…
2Cases cited13 opinions
- R. H. Stearns Co. v. United StatesSupreme Court of the United States · 1934
- Piarulle v. Comm'rUnited States Tax Court · 1983
- Joyce v. GentschCourt of Appeals for the Sixth Circuit · 1944
- Dimitrious J. Lignos and Evelyn Lignos v. United StatesCourt of Appeals for the Second Circuit · 1971
- Pancoast Hotel Co. v. CommissionerUnited States Tax Court · 1943
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3Cited by22 opinions
- Estate of Hilda Ashman v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2000
- Lockheed Sanders, Inc. v. United StatesDistrict Court, D. New Hampshire · 1994
- Steiner v. CommissionerUnited States Tax Court · 1995
- Leader Federal Sav. & Loan Ass'n v. CommissionerUnited States Tax Court · 1989
- Union Tex. Int'l Corp. v. CommissionerUnited States Tax Court · 1998
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