Regal, Inc. v. Commissioner
United States Tax Court
T corporation and its 19 wholly owned subsidiary corporations elected to file a consolidated Federal income tax return for their fiscal year ended Jan. 31, 1964. For the taxable year ended Jan. 31, 1965, T corporation and its subsidiaries filed separate returns.
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T corporation and its 19 wholly owned subsidiary corporations elected to file a consolidated Federal income tax return for their fiscal year ended Jan. 31, 1964. For the taxable year ended Jan. 31, 1965, T corporation and its subsidiaries filed separate returns. Sec. 1.1502-11A(a), Income Tax Regs., provides that, with certain exceptions not applicable here, if an affiliated group of corporations elects to make a consolidated return for any taxable year a consolidated return must be made for each subsequent taxable year during which the consolidated group remains in existence. Held, these…
1Opinion of the Court
Regal, Incorporated, Petitioner v. Commissioner of Internal Revenue, Respondent
Regal, Inc. v. Commissioner
Docket No. 3937-67
United States Tax Court
53 T.C. 261; 1969 U.S. Tax Ct. LEXIS 22;
November 17, 1969, Filed
Decision will be entered for the respondent.
T corporation and its 19 wholly owned subsidiary corporations elected to file a consolidated Federal income tax return for their fiscal year ended Jan. 31, 1964. For the taxable year ended Jan. 31, 1965, T corporation and its subsidiaries filed separate returns. Sec. 1.1502-11A(a), Income Tax Regs., provides that, with certain exceptions not…
2Cases cited16 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- United States v. CorrellSupreme Court of the United States · 1967
- Bingler v. JohnsonSupreme Court of the United States · 1969
- Brewster v. GageSupreme Court of the United States · 1930
- Sanford v. CommissionerUnited States Tax Court · 1968
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