Lone Star Life Insurance Company - Page 18

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          for redetermination were filed with the Court with respect to               
          each notice.  However, INI, Inc. (INI), the subsidiary                      
          corporation, subsequently challenged the validity of the notice             
          of deficiency that respondent had issued to INI on the ground               
          that the separate notice was issued in violation of section                 
          1.1502-77(a), Income Tax Regs.                                              
               Contrary to INI's position, the Court sustained the validity           
          of the notice of deficiency.  In particular, although recognizing           
          that a common parent of a consolidated group of corporations                
          normally serves as agent for its subsidiaries, the Court observed           
          that a copy of the notice of deficiency issued to INI was                   
          contemporaneously furnished to the common parent corporation.               
          Under the circumstances, the Court concluded that the notice of             
          deficiency was validly issued pursuant to the consolidated return           
          regulations on the ground that it served as notice to the common            
          parent corporation that respondent intended to deal directly with           
          INI pursuant to the final sentence of section 1.1502-77(a),                 
          Income Tax Regs.                                                            
               Applying similar reasoning in the present case, we conclude            
          that the April 11, 1996, notice of deficiency issued to                     
          petitioner is valid.  Of course, the facts in the present case              
          can be distinguished from those of INI, Inc. v. Commissioner,               
          supra, insofar as respondent did not directly furnish Hibiscus              
          with a copy of the April 11, 1996, notice of deficiency.                    





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