Coggin Auto. Corp. v. Commissioner
United States Tax Court
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.
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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 inventories of automobiles and light trucks under the dollar-value LIFO method of accounting. P did not directly own any inventory. From Jan. 29, 1970 (the date of…
1Opinion of the Court
JACOBS, Judge:
Respondent determined deficiencies in petitioner’s Federal income taxes as follows:
TYE Deficiency
June 26, 1993 . $432,619
Dec. 31, 1993 . 432,619
Dec. 31, 1994 . 432,619
Dec. 31, 1995 . 432,619
These deficiencies stem from respondent’s determination requiring petitioner to recapture its LIFO reserves upon conversion from a C corporation to an S corporation effective June 27, 1993.
The issue for decision is whether petitioner is subject to LIFO recapture pursuant to section 1363(d) as a consequence of a change in the structure of petitioner and its subsidiaries. For the reasons set…
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