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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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