115 T.C. No. 28 UNITED STATES TAX COURT COGGIN AUTOMOTIVE CORPORATION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 1684-99. Filed October 18, 2000. P was a holding company that held over 80 percent of the stock of five corporations (collectively, the subsidiaries) that were engaged in the retail sales of automobiles and light trucks conducted through six dealerships. From 1972 or 1973 until and including the fiscal year ended June 26, 1993, P (as common parent) filed consolidated corporate income tax returns with its subsidiaries. The subsidiaries maintained their inventories of automobiles and light trucks under the dollar-value LIFO method of accounting. P did not directly own any inventory. From Jan. 29, 1970 (the date of incorporation), until June 27, 1993, P was a C corporation. On or about Aug. 27, 1993, P elected S corporation status, effective June 27, 1993. The election was made pursuant to a restructuring plan. The restructuring resulted in the establishment of six new S corporations formed for the purpose of becoming general partners in six limited partnerships that would operate the six dealerships. Each subsidiary contributed the assets and liabilities ofPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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