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through 1992 taxable years, CGF was the common parent of an
affiliated group of corporations making a consolidated return of
income. By notices of deficiency respondent determined defi-
ciencies in Federal income taxes of the CGF affiliated group in
the following amounts:
Fiscal Year Ending Deficiency
1988 $4,369,352
1989 745,105
1990 362,525
1991 259,708
1992 214,805
Likewise, Lincoln Industries, Inc. (Lincoln), uses a fiscal
year ending on March 31 to compute its income. For taxable years
1989 through 1993, Lincoln was the common parent of an affiliated
group of corporations making a consolidated return of income. By
notices of deficiency respondent determined deficiencies in
Federal income taxes of the Lincoln affiliated group in the
following amounts:
Fiscal Year Ending Deficiency
1989 $294,285
1990 562,953
1991 562,653
1992 562,306
1993 578,561
By order of this Court dated January 19, 1995, these cases
were consolidated for purposes of trial, briefing, and opinion.
In a stipulation of partial settlement filed with the Court on
January 18, 1995, respondent conceded all deficiencies determined
against CGF and its subsidiaries for 1988, thus removing all
issues relating to the 1988 tax year from consideration in these
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