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the meaning of section 1504(a) or amended section 1504(a) that
had Amax as its common parent, Amax and its successor Cyprus Amax
each had both actual authority and apparent authority to act on
behalf of Alumax and the other members of petitioners' group when
each executed one or more of the Forms 872 in question. Accord-
ingly, we further find that the respective periods of limitations
for the years 1984, 1985, and 1986 for the assessment of tax due
from petitioners' group have not expired.
To reflect the foregoing,44
Decision will be entered
for respondent.
44 The correlative issues involving certain claimed general
business credit carrybacks also are resolved against petitioners'
group in light of our holdings on the principal issues presented.
See supra note 3.
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