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
OPINION
Eaum, Judge:
The Commissioner determined a deficiency in the income tax of petitioner for the taxable year ended January 31, 1965, in the amount of $64,347.39. At issue is whether petitioner and its subsidiaries were required to file a consolidated Federal income tax return for their taxable year ended January 31, 1965, solely because they elected to file a consolidated Federal income tax return for the previous taxable year. Whether they were required to do so depends upon the validity of section 1.1502-llA'(a) of the regulations, in effect during the years here in issue, which provide…
2Cases cited15 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
10 more not listed; retrieve them via the Exa API.
3Cited by29 opinions
- Georgia-Pacific Corp. v. CommissionerUnited States Tax Court · 1975
- Regal, Incorporated v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1970
- Garvey, Inc. v. United StatesUnited States Court of Claims · 1983
- Matheson v. CommissionerUnited States Tax Court · 1980
- Covil Insulation Co. v. CommissionerUnited States Tax Court · 1975
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