Dividend Industries, Inc. v. Commissioner
United States Tax Court
Petitioner is the common parent of an affiliated group of corporations which filed consolidated Federal income tax returns for 1977, 1978, 1979, and 1980. Respondent mailed to petitioner notices of deficiency which determined deficiencies in the 1977 through 1980 Federal income tax liabilities of the affiliated group.
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Petitioner is the common parent of an affiliated group of corporations which filed consolidated Federal income tax returns for 1977, 1978, 1979, and 1980. Respondent mailed to petitioner notices of deficiency which determined deficiencies in the 1977 through 1980 Federal income tax liabilities of the affiliated group. The notices of deficiency, however, made no reference to an affiliated group and did not identify any of petitioner's subsidiary corporations even though the deficiencies are attributable solely to adjustments to income, deduction, and credit items of the subsidiary…
1Opinion of the Court
OPINION
SWIFT, Judge:
This matter is before the Court on petitioner’s motion to dismiss for lack of jurisdiction. The issue raised by the motion is whether respondent’s notices of deficiency, which were mailed to petitioner as the parent of an affiliated group of corporations, are invalid because the notices reflect adjustments attributable solely to income, deduction, and credit items of petitioner’s subsidiary corporations, none of which was identified in the notices of deficiency. Petitioner also moves for summary judgment against respondent on the ground that none of the adjustments set…
2Cases cited6 opinions
- Peninsula Steel Products & Equipment Co. v. CommissionerUnited States Tax Court · 1982
- Anheuser-Busch, Inc. v. CommissionerUnited States Board of Tax Appeals · 1939
- Intervest Enterprises, Inc. v. CommissionerUnited States Tax Court · 1972
- Mississippi River & Bonne Terre Ry. v. CommissionerUnited States Board of Tax Appeals · 1939
- Wobber Bros. v. CommissionerUnited States Board of Tax Appeals · 1934
1 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Normac, Inc. v. CommissionerUnited States Tax Court · 1988
- First Chicago Corp. v. CommissionerUnited States Tax Court · 1987
- Dividend Industries, Inc. v. CommissionerUnited States Tax Court · 1987
- First Chicago Corp. v. CommissionerUnited States Tax Court · 1987
- Normac, Inc. v. CommissionerUnited States Tax Court · 1988