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Systems Corp. (Controlled Casting), National For Sale by Owner
Realty Corp. (Sale By Owner), National Industrial Management
Corporation (Industrial Management), and Far Western Real Estate
Corp. (Far Western). For the years for which petitioner's
returns show consolidated losses, the separate gains and losses
of petitioner and its subsidiaries are as follows:
Total Controlled Industrial Sale By Far
Year Loss NII Casting Management Owner Western
1989 ($35,229) ($35,229) * * * *
1988 (32,766) (32,716) * * * (50)
1985 (46,115) (41,602) * (3,995) (408) (110)
1984 (35,992) (4,814) * (11,594) 3,722 (23,306)
1983 (38,514) 7,188 * (13,821) (5,232) (26,949)
1982 (47,378) (25,720) * (1,709) (19,949) *
1978 (40,328) (2,565) * (37,763) * *
1976 (19,941) (36,113) (486) 16,658 * *
* represent years in which petitioner's consolidated return did not include
the subsidiary.
Controlled Casting emerged from an arrangement between
Sears, an inventor, and Shell Chemical Company (Shell). They
sought to develop a new type of foundry equipment, which, by
injecting sand with a resin-type material, could form the mixture
into molds. Sears and Shell agreed that if Shell would develop
the resin and give Sears a 10-year license, then he, in turn,
would design the machine. Shell subsequently formulated the
resin from benzene, a petroleum derivative.
Sears incorporated Controlled Casting and, in 1973, sold 80
percent of its stock to petitioner. Not only did Controlled
Casting design the machine, but it also manufactured several of
them and sold two to General Motors. However, shortly
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