Century Data Systems, Inc. v. Commissioner
United States Tax Court
Petitioner joined in the filing of consolidated returns of a group of related corporations. Such consolidated returns were filed on the basis of fiscal years ended June 30, 1970, and June 30, 1971. Petitioner continued to keep its books on the basis of calendar years. Respondent determined petitioner was not an affiliated member and, thus, was not entitled to join in such consolidated returns.
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Petitioner joined in the filing of consolidated returns of a group of related corporations. Such consolidated returns were filed on the basis of fiscal years ended June 30, 1970, and June 30, 1971. Petitioner continued to keep its books on the basis of calendar years. Respondent determined petitioner was not an affiliated member and, thus, was not entitled to join in such consolidated returns. Therein, respondent issued a notice of deficiency based on petitioner's fiscal years ended June 30, 1970, and June 30, 1971. In the same notice of deficiency, respondent determined a deficiency for…
1Opinion of the Court
OPINION
Fay, Judge:
Respondent determined the following deficiencies in and additions to petitioner Century Data Systems, Inc.’s Federal income tax for the following taxable years:1
Additions to tax
Taxable year or period ended Deficiency sec. 6653(a)2
June 30, 1970 $28,044.59 0
June 30, 1971 6,202,136.50 $310,106.83
Mar. 31, 1972 945,551.13 47,277.56
This case is before the Court on petitioners’ motion for judgment on the pleadings under Rule 120.
Both petitioners, Century Data Systems, Inc. (hereafter petitioner) and California Computer Products, Inc. (hereafter Cal Comp), had their principal places…
2Cases cited25 opinions
- R. H. Stearns Co. v. United StatesSupreme Court of the United States · 1934
- Sanderling, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1978
- Sanderling, Inc. v. CommissionerUnited States Tax Court · 1976
- Commissioner of Internal Revenue v. Forest Glen C. Co.Court of Appeals for the Seventh Circuit · 1938
- Gensinger v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1953
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3Cited by11 opinions
- Century Data Sys. ex rel. California Computer Prods. v. CommissionerUnited States Tax Court · 1986
- Page v. CommissionerUnited States Tax Court · 1986
- Lockheed Sanders, Inc. v. United StatesDistrict Court, D. New Hampshire · 1994
- Miles Production Company v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1993
- Miles Production Co. v. CommissionerUnited States Tax Court · 1991
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