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and, at all relevant times, was the common parent of a group of
corporations that filed consolidated corporate Federal income tax
returns. At the time the petitions were filed in these cases,
GENDYN's and GENDYN/FSC’s principal places of business were in
Falls Church, Virginia. GENDYN engineered, developed, and
manufactured various products for the U.S. Government and, to a
lesser extent, foreign governments, including military aircraft,
missiles, gun systems, space systems, tanks, submarines,
electronics, and other miscellaneous goods and services. GENDYN
was also involved in business activities, including design,
engineering, and manufacture of general aircraft; mining coal,
lime, limestone, sand, and gravel; manufacture and sale of ready-
mix concrete, concrete pipe, and other building products;
production of commercial aircraft subassemblies; design,
engineering, and manufacture of commercial space launch vehicles
and services; and shipbuilding. GENDYN, for the taxable years
1977 through 1986, used the completed contract method to report
Federal income and the percentage of completion method for its
financial accounting purposes.
GENDYN, on February 25, 1972, incorporated an entity
(GENDYN/DISC)2 to serve as an export sales representative.
2 The issues in these consolidated cases span a time period
within which the statutory provisions relating to domestic
international sales corporations were replaced by those related
to foreign sales corporations. Due to these statutory changes,
GENDYN ended use of its specially formed domestic international
(continued...)
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