- 3 - stipulation of facts is incorporated in this opinion by reference and found accordingly. Intermet, a Georgia corporation, had its principal office in Troy, Michigan, when it filed the petition in the instant case. Intermet is the common parent of an affiliated group of corporations (the group) that manufactures precision iron castings for automotive and industrial equipment producers. For calendar years 1984 through 1993, the group filed consolidated Federal income tax returns. During those years, all members of the group used the accrual method of accounting for both financial accounting and Federal income tax purposes. Lynchburg was a member of the group during each year from 1984 through 1993. On its 1992 consolidated Federal income tax return, the group reported a consolidated net operating loss (CNOL) in the amount of $25,701,038. During October 1994, the group filed Form 1120X, Amended U.S. Corporation Income Tax Return, claiming a carryback to 1984 for specified liability losses incurred during 1992, in the amount of $1,227,973. During 1992, the group's CNOL exceeded the sum of the claimed specified liability losses. Members of the group that claimed specified liability losses reported separate taxable income, as defined in section 1.1502- 12, Income Tax Regs., and specified liability loss deductions as follows:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011