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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