Davis Bros. Restaurant, Inc. v. Commissioner
United States Tax Court
For several years prior to their fiscal year 1967, petitioners, members of a controlled group of corporations, had filed their income tax returns and computed their tax with the benefit of the multiple surtax exemptions authorized by sec. 1562, I.R.C. 1954. For the fiscal year 1967, two of the corporations, members of an affiliated group as defined in sec. 1504, I.R.C. 1954, filed a single return, combining their income, deductions, and credits, and otherwise (except in…
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For several years prior to their fiscal year 1967, petitioners, members of a controlled group of corporations, had filed their income tax returns and computed their tax with the benefit of the multiple surtax exemptions authorized by sec. 1562, I.R.C. 1954. For the fiscal year 1967, two of the corporations, members of an affiliated group as defined in sec. 1504, I.R.C. 1954, filed a single return, combining their income, deductions, and credits, and otherwise (except in certain specific respects) complying with the regulations on the filing of consolidated returns. Other members of the…
1Opinion of the Court
FeatheRSton, Judge:
Respondent determined deficiencies in petitioners’ income tax for the fiscal year ending September 30, 1967, as follows:
Docket No. Petitioner Deficiency
6484-71_Davis Bros. Restaurant, Inc___$2,201. 45
6486-71_Fancy Foods, Inc_ 824. 41
6487-71_Davis Bros. Management Corp_ 24, 339. 47
6488-71_Georgia Restaurant Co_1 4,133. 34
6489-71_Reginald Investment Co_ 3, 308. 75
6490-71_Davis Bros., Inc_.._ 7,110. 46
6491-71_Davis Bros., Inc. of Tennessee_ 1, 406. 65
6492i-71_Davis Bros., Inc. of Marietta_ 4, 566. 67
6493-71_Davis Bros. North DeKalb, Inc_ 4, 566. 67
6494-71_Davis Bros. Bolton,…
2Cases cited8 opinions
- Regal, Inc. v. CommissionerUnited States Tax Court · 1969
- Regal, Incorporated v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1970
- Patten Fine Papers, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1957
- American Trans-Ocean Navigation Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1956
- Landy Towel & Linen Service, Inc. v. CommissionerUnited States Tax Court · 1962
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3Cited by5 opinions
- Millette & Associates, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1979
- Craigie, Inc. v. CommissionerUnited States Tax Court · 1985
- Millette & Associates, Inc. v. CommissionerUnited States Tax Court · 1978
- Craigie, Inc. v. CommissionerUnited States Tax Court · 1985
- Davis Bros. Restaurant, Inc. v. CommissionerUnited States Tax Court · 1973