Alumax Inc. and Consolidated Subsidiaries - Page 1

                                   109 T.C. No. 8                                     


                               UNITED STATES TAX COURT                                


              ALUMAX INC. AND CONSOLIDATED SUBSIDIARIES, Petitioners v.               
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 7779-95.                Filed September 30, 1997.           


                    For certain years prior to the period at issue,                   
               petitioners, company A (A) and its subsidiaries (A                     
               group), were members of an affiliated group of corpora-                
               tions within the meaning of sec. 1504(a)1 that had A as                
               its common parent, which filed consolidated returns for                
               those corporations.  During that time, A had issued and                
               outstanding two classes of stock, each of which pos-                   
               sessed 50 percent of the voting power of all classes of                
               its stock, one class of which was held by certain                      
               corporations (B group stockholders) who were members of                
               an affiliated group of corporations (B group) within                   
               the meaning of sec. 1504(a), and the other class of                    
               which was held by certain other corporations (C group                  
               stockholders).  Company B (B) filed consolidated re-                   

          1  Unless otherwise indicated, all section references are to the            
          Internal Revenue Code (Code) in effect for the years at issue.              
          All Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  




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