- 3 - OPINION2 CHIECHI, Judge: Respondent determined the following defi- ciencies in petitioners' Federal income tax: Taxable Year Ended Deficiency Dec. 31, 1981 $5,663,086 Dec. 31, 1983 11,454,565 Dec. 31, 1984 40,433,142 Dec. 31, 1985 48,511,681 Nov. 24, 19861 23,175,558 1 We shall refer to the taxable year ended Nov. 24, 1986, as 1986. The principal issues for decision are:3 (1) Were petitioners members of the affiliated group within the meaning of section 1504(a) that had Amax Inc. (Amax) as its common parent, which filed a consolidated Federal income tax return (consolidated return) for each of the years 1984, 1985, and 1986 that included petitioners?4 We hold that they were not 2 Unless otherwise indicated, our Opinion pertains to the years 1984, 1985, and 1986 (period at issue). 3 Correlative issues also remain as to whether petitioners are entitled for 1981 and 1983 to general business credits that they carried back (1) from 1984 to 1981 and (2) from 1985 and 1986 to 1983. Respondent claims, and petitioners do not dispute, that resolution of those correlative issues is governed by the Court's holdings on the principal issues presented. 4 We shall sometimes refer (1) to the corporations that are petitioners in this case and that were included in the consoli- dated returns filed by Amax as the common parent of an affiliated group for the years 1984, 1985, and 1986 as petitioners' group and (2) to Amax and its subsidiaries, excluding petitioners' group, that were included in those consolidated returns as the Amax group.Page: Previous 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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