Legal Opinion

Alumax Inc. v. Commissioner

United States Tax Court

Decided September 30, 1997No. Tax Ct. Dkt. No. 7779-95Published

For certain years prior to the period at issue, petitioners, company A (A) and its subsidiaries (A group), were members of an affiliated group of corporations within the meaning of sec. 1504 (a)1Unless otherwise indicated, all section references are to the Internal Revenue Code (Code) in effect for the years at issue.

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For certain years prior to the period at issue, petitioners, company A (A) and its subsidiaries (A group), were members of an affiliated group of corporations within the meaning of sec. 1504 (a)1Unless otherwise indicated, all section references are to the Internal Revenue Code (Code) in effect for the years at issue. All Rule references are to the Tax Court Rules of Pactice and Procedure. that had A as its common parent, which filed consolidated returns for those corporations. During that time, A had issued and sic outstanding two classes of stock, each of which possessed 50 percent of the…

1Opinion of the Court

ALUMAX INC. AND CONSOLIDATED SUBSIDIARIES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Alumax Inc. v. Commissioner

Tax Ct. Dkt. No. 7779-95

United States Tax Court

109 T.C. 133; 1997 U.S. Tax Ct. LEXIS 59; 109 T.C. No. 8;

September 30, 1997, Filed

For certain years prior to the period at issue, petitioners, company A (A) and its subsidiaries (A group), were members of an affiliated group of corporations within the meaning of sec. 1504 (a)1 that had A as its common parent, which filed consolidated returns for those corporations. During that time, A had issued and sic outstanding two…

2Cases cited49 opinions

  1. Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
  2. Welch v. HelveringSupreme Court of the United States · 1933
  3. Metcalf & Eddy v. MitchellSupreme Court of the United States · 1926
  4. Buffalo Tool & Die Mfg. Co. v. CommissionerUnited States Tax Court · 1980
  5. Seymour Silverman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976

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