Interlake Corporation - Page 7




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          transaction in which petitioner became the successor common                  
          parent of the group.                                                         
               On or about September 14, 1987, the service center, after               
          processing petitioner's application, made a tentative refund                 
          allowance to petitioner in the amount of $5,346,097.  The service            
          center charged the tentative refund allowance to the Federal                 
          income tax account of the group for 1984 (i.e., to the tax                   
          account of Acme).                                                            
               Acme                                                                    
               Acme and its wholly owned domestic subsidiary, AMC, had a               
          short taxable year for 1986, which short taxable year began on               
          June 23 and ended on December 28.  On their consolidated Federal             
          income tax return for the 27-week short taxable year ended on                
          December 28, 1986, Acme, and its consolidated subsidiary, AMC,               
          reported a CNOL in the amount of $29,286,968, the entire amount              
          of which was attributable to Acme.  The return was prepared on               
          the basis that, after the spinoff, Acme and its consolidated                 
          subsidiary, AMC, constituted a new consolidated group, which was             
          unrelated to petitioner and the group.                                       
               On or about September 17, 1987, Acme and its consolidated               
          subsidiary filed, with the service center, two Forms 1139,                   
          Corporation Application for Tentative Refund.  On the first Form             
          1139, Acme and its consolidated subsidiary requested a tentative             
          refund of income tax in the amount of $11,298,371, attributable              
          to the carryback of the Acme 1986 short-year CNOL to Acme's                  
          (i.e., the group's) 1984 and 1985 tax years.  Included in the                

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