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Background
Most of the facts have been stipulated and are so found.
The stipulation of facts, the supplemental stipulation of facts,
the stipulation of partial settlement, the stipulation of settled
issues and the attached exhibits are incorporated herein by this
reference. At the time it filed the petition, GM had its
principal place of business in Detroit, Michigan.
I. General Background
GM is a corporation duly organized under the laws of the
State of Delaware, doing business directly and through
subsidiaries in the United States and abroad. For 1985 and all
relevant prior and subsequent years, GM filed a consolidated
Federal income tax return, Form 1120, on a calendar year basis on
behalf of GM and its consolidated affiliated subsidiaries within
the meaning of section 1504. In 1985 and all relevant prior and
subsequent years, General Motors Acceptance Corporation (GMAC), a
wholly owned subsidiary of GM, was part of the GM group. GM and
GMAC both maintain their books and records, and report their
income for Federal income tax purposes, using the accrual method
of accounting.
At all relevant times, GM was a multiplant manufacturing
enterprise primarily engaged in the design, manufacture,
assembly, and sale of motor vehicles (including automobiles,
trucks, and buses) and related parts and accessories.
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Last modified: May 25, 2011