Applied Research Associates, Inc. & Affiliate v. Commissioner
United States Tax Court
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 qualified personal service corporation, P paid tax on the consolidated…
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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 qualified personal service corporation, P paid tax on the consolidated taxable income of the affiliated group at graduated rates set forth in I.R.C. sec. 11(b)(1). On the basis that each…
1Opinion of the Court
OPINION
Jacobs, Judge:
The parties submitted this case fully stipulated pursuant to Rule 122. Applied Research Associates, Inc. (Applied Research), is a corporation organized under the laws of Tennessee. It provides professional engineering and consulting services and is a qualified personal service corporation as defined in section 448(d)(2). During the years involved (2006 and 2007) Applied Research owned all the outstanding stock of Oak Crest Land & Cattle Co., Inc. (Oak Crest), a Texas corporation. During the years involved Oak Crest owned and operated a 400-acre ranch in Texas which owned…
2Cases cited8 opinions
- Handy & Harman v. BurnetSupreme Court of the United States · 1931
- Woods Inv. Co. v. CommissionerUnited States Tax Court · 1985
- Henry C. Beck Builders, Inc. v. CommissionerUnited States Tax Court · 1964
- Gottesman & Co. v. CommissionerUnited States Tax Court · 1981
- Norwest Corp. v. Comm'rUnited States Tax Court · 1998
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3Cited by4 opinions
- Duquesne Light Holdings Inc v. Commissioner of Internal RevenCourt of Appeals for the Third Circuit · 2017
- Guidant LLC v. Comm'rUnited States Tax Court · 2016
- Applied Research Associates, Inc. and Affiliate v. CommissionerUnited States Tax Court · 2014
- Duquesne Light Holdings Inc v. Commissioner of Internal RevenCourt of Appeals for the Third Circuit · 2017