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petitioner's net subpart F income includable in petitioner's
gross income for the taxable year 1986.1
Background
This case was submitted fully stipulated under Rule 122.2
The stipulation of facts and accompanying exhibits are
incorporated herein by this reference and found accordingly.
Petitioner, an accrual basis taxpayer, is a corporation
having its principal offices in Maumee, Ohio, at the time it
filed the petition herein. Petitioner changed its name to
Trinova from the Libbey-Owens-Ford Company on July 31, 1986. It
timely filed a consolidated Federal income tax return with
certain of its subsidiaries for each of the years at issue either
with the Internal Revenue Service Center, Cincinnati, Ohio, or
the Internal Revenue Service office in Toledo, Ohio.
Throughout 1986, petitioner owned 100 percent of Aeroquip
International, Inc. (AII), a Delaware corporation, which in
turned owned 100 percent of Aeroquip, AG (AG), a Swiss
corporation. During 1986, AG was a "controlled foreign
1 An additional issue, relating to investment tax credit
recapture under sec. 47, has been disposed of in a prior opinion.
Trinova Corp. and Subs. v. Commissioner, 108 T.C. ___ (1997).
2 Unless otherwise indicated, all section references are to the
Internal Revenue Code in effect for the taxable years in issue,
and all Rule references are to the Tax Court Rules of Practice
and Procedure.
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