Alumax Inc. and Consolidated Subsidiaries - Page 18

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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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