General Dynamics Corporation and Subsidiaries - Page 4

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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             

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