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application package was a copy of petitioner's Form 1120X,
Amended U.S. Corporation Income Tax Return, for the taxable year
1984.2 That Form 1120X indicates that petitioner is the
"Successor in interest to Interlake, Inc. [i.e., Acme] and
Consolidated Subsidiaries."
On the second Form 1139, Acme and its consolidated
subsidiary requested a tentative refund of income tax in the
amount of $148,692 attributable to the carryback of $174,931 of
investment tax credits and certain credits for increasing
research activity from Acme's (i.e., the group's) 1984 tax year
to Acme's (i.e., the group's) 1981 tax year.3
After reviewing the two Forms 1139 filed by Acme and its
consolidated subsidiary, the service center advised Acme that it
could not process the first Form 1139 (relating to 1984 and 1985)
as filed because it did not take into account the tentative
refund allowance previously made to petitioner and the group with
respect to Acme's (i.e., the group's) 1984 tax year. Acme then
filed, on or about October 26, 1987, a revised Form 1139 for tax
2 Petitioner filed the Form 1120X on or about Oct. 31, 1986,
subsequent to the restructuring transaction and spinoff, to
eliminate $2,120,691 of investment tax credit (ITC) carryovers
from 1982 and 1983. As a result of an Internal Revenue Service
audit, the group's tax liability for 1980 and 1981 was
sufficiently increased to absorb the 1982 and 1983 ITC's as
carrybacks.
3 Acme also filed Form 8302, Application for Electronic Funds
Transfer of Tax Refund of $1 Million or More, in which it
requested that the tentative refunds for 1984 and 1985 be wired
to an account maintained by Acme at the First Natl. Bank of
Chicago.
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