- 4 -
and that therefore petitioners may not join in any of those
consolidated returns.
(2) Has the period of limitations under section 6501 for
each of the years 1984, 1985, and 1986 for the assessment of tax
due from petitioners' group expired? We hold that it has not.
This case was submitted fully stipulated. All of the facts
that have been stipulated are so found unless otherwise stated
herein.
General
Alumax Inc. (Alumax), a Delaware corporation organized by
Amax on October 17, 1973, had its principal place of business in
Norcross, Georgia, at the time the petition was filed.5 At all
relevant times Alumax has been an integrated aluminum company
engaged in the production and sale of primary aluminum, semi-
fabricated products, and diverse fabricated products.
Amax, a New York corporation organized in 1887, has been at
all relevant times a worldwide supplier of metals and energy, as
well as a manufacturer and distributor of metals-related products
and chemicals.6 Prior to December 5, 1973, Amax' principal
businesses were in aluminum, coal, gold, and molybdenum. Amax
conducted the aluminum business, which it had entered during
5 Since its incorporation, Alumax has operated under different
names.
6 Since its incorporation, Amax has operated under different
names.
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