Intermet Corporation & Subsidiaries - Page 3

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          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:                                                                    





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