Coggin Automotive Corporation v. Commissioner

115 T.C. No. 28

UNITED STATES TAX COURT COGGIN AUTOMOTIVE CORPORATION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 1684-99. Filed October 18, 2000. P was a holding company that held over 80 percent of the stock of five corporations (collectively, the subsidiaries) that were engaged in the retail sales of automobiles and light trucks conducted through six dealerships. From 1972 or 1973 until and including the fiscal year ended June 26, 1993, P (as common parent) filed consolidated corporate income tax returns with its subsidiaries. The subsidiaries maintained their…