Legal Opinion

Alumax Inc. v. Commissioner

United States Tax Court

Decided September 30, 1997No. Tax Ct. Dkt. No. 7779-95PublishedCited by 30 opinions

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

OPINION2

Chiechi, Judge:

Respondent determined the following deficiencies in petitioners’ Federal income tax:

TYE Deficiency

Dec. 31, 1981 . $5,663,086

Dec. 31, 1983 . 11,454,565

Dec. 31, 1984 . 40,433,142

Dec. 31, 1985 . 48,511,681

Nov. 24, 19861 23,175,558

The principal issues for decision are:3(1) Were petitioners members of the affiliated group within the meaning of section 1504(a) that had Amax Inc. (Amax) as its common parent, which filed a consolidated Federal income tax return (consolidated return) for each of the years 1984, 1985, and 1986 that included petitioners?4 We hold that they were…

2Cases cited48 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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3Cited by30 opinions

  1. Olive v. CommissionerUnited States Tax Court · 2012
  2. Norwest Corp. v. Comm'rUnited States Tax Court · 1998
  3. Baker v. Comm'rUnited States Tax Court · 2004
  4. Framatome Connectors USA, Inc. v. Comm'rUnited States Tax Court · 2002
  5. Gibson & Associates, Inc. v. CommissionerUnited States Tax Court · 2011

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

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