- 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