- 3 -
FINDINGS OF FACT
Unless otherwise indicated, all Rule references are to the
Tax Court Rules of Practice and Procedure, and all section
references are to the Internal Revenue Code in effect for the
years in issue. Some of the facts have been stipulated for trial
pursuant to Rule 91. The parties' stipulations are incorporated
in this Memorandum Opinion by reference and are found accordingly
except as noted below with respect to certain stipulations to
which objections were reserved.
General Background
The principal place of business of both CV and CVI was
Bedford, Massachusetts, at the time each filed its petition in
the instant case. CV, a Delaware corporation, designs,
manufactures, and sells computer-aided design, computer-aided
manufacturing, and computer-aided engineering (CAD/CAM/CAE)
products. CV maintains its books and records on an accrual
accounting basis using a calendar year.2 During relevant
periods, CVI, a Massachusetts corporation, maintained its books
and records on an accrual accounting basis using a fiscal year
ending January 31.3 During CV's and CVI's taxable years ending
2
In 1988, however, CV, together with at least certain of its
subsidiaries, filed a consolidated Federal income tax return for
the period beginning Jan. 1, 1988, and ending Feb. 5, 1988.
3
In 1985, however, CVI, filed a Form 1120-DISC for the period
(continued...)
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011