5
secretary. At the time of filing of Alondra's petition, its
principal place of business was at 1001 El Centro Street, South
Pasadena, California (the El Centro property).
Edco is a California corporation. Edco keeps its books and
reports its income using the accrual method of accounting on a
fiscal year ending September 30. Mr. Munro, Ms. Ross's father,
is Edco's sole shareholder. At the time of filing of Edco's
petition, its principal place of business was at the El Centro
property.
United California Insulation Company (UCIC) is a wholly
owned subsidiary of United California Industries, Inc. (UCII);
both of them are California corporations, and their income,
deductions, and credits are reported on consolidated corporation
income tax returns.3 The principal place of business of both
UCIC and UCII is at the El Centro property. Mr. Munro is UCII's
sole shareholder. UCII keeps its books and reports its income
using the accrual method of accounting and a calendar year.
Neither UCIC nor UCII is a petitioner in this Court.4
3According to UCII's consolidated return for 1987, UCIC was
one of three subsidiaries of UCII, but was by far the dominant
member, accounting for some 77 percent of the UCII affiliated
group's total gross receipts.
4Respondent determined a deficiency and additions against
UCII for 1987, employing adjustments to the income of UCII
similar to those against Alondra and Edco for their fiscal 1987,
but the deficiency and additions are not in dispute, having been
settled administratively. At some undetermined time after 1987
and before trial of the cases at hand, UCII and/or UCIC filed for
(continued...)
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