Applied Research Associates, Inc. and Affiliate v. Commissioner

143 T.C. No. 17

UNITED STATES TAX COURT APPLIED RESEARCH ASSOCIATES, INC. AND AFFILIATE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 21076-11. Filed October 9, 2014. P, an affiliated group consisting of a qualified personal service corporation A, the parent corporation, and a corporation that is not a qualified personal service corporation, filed consolidated Federal income tax returns for 2006 and 2007. P reported consolidated taxable income for 2006 and 2007, all of which was attributable to A. On the basis that the affiliated group, as a single entity, was not a…