Legal Opinion

Century Data Systems, Inc. v. Commissioner

United States Tax Court

Decided March 8, 1983No. Docket No. 2227-76Published

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.

Read the full summary

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

Century Data Systems, Inc., and California Computer Products, Inc., Petitioners v. Commissioner of Internal Revenue, Respondent

Century Data Systems, Inc. v. Commissioner

Docket No. 2227-76

United States Tax Court

80 T.C. 529; 1983 U.S. Tax Ct. LEXIS 108; 80 T.C. No. 24;

March 8, 1983, Filed

An order dismissing the case for lack of jurisdiction will be entered.

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…

2Cases cited26 opinions

  1. R. H. Stearns Co. v. United StatesSupreme Court of the United States · 1934
  2. Sanderling, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1978
  3. Sanderling, Inc. v. CommissionerUnited States Tax Court · 1976
  4. Commissioner of Internal Revenue v. Forest Glen C. Co.Court of Appeals for the Seventh Circuit · 1938
  5. Gensinger v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1953

21 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API